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Privacy Policy

Pulse Finance Limited · Last reviewed: June 2026

This Privacy Policy is intended to provide you with information about how the Pulse Group of companies gathers and uses your personal data. The Pulse Group companies all collect and share your data as per the terms of this Policy. All data collected by each company is shared between the Group companies. The Pulse Group is the data controller, who is committed to the protection of your privacy. When we refer to “Pulse”, “we”, “us” or “our” we are talking about all the companies within the Pulse Group.

We have appointed a data protection compliance officer who is in charge of answering questions in relation to this policy. If you have any questions about it or if you want to use any of your legal rights, please contact the data protection compliance officer using the details set out below.

All personal information given to us through this website will only be held and used in accordance with this policy, the Privacy and Electronic Communications (E.C. Directive) Regulations 2003 (as amended), the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018.

Data Protection Compliance Officer

Postal Address
Data Protection Compliance Officer, The Pulse Group of Companies, The Grosvenor, Basing View, Basingstoke, Hampshire, RG21 4HG

Telephone
01256 976029

Email
compliance@pulsefinancelimited.com

Information We Collect and Store

We use different methods to collect data from and about you including through:

Direct Interactions

You may give us your information by filling in forms, via webchat on our website, on the telephone, or by corresponding with us by post, fax, email or otherwise. This includes personal data you provide when you:

  • ask us to send information to you;
  • provide us (yourself or on behalf of an organisation) with goods or services or obtain products and services from us; or
  • provide us feedback or contact us about our products or services.

Third Parties or Publicly Available Sources

We may receive personal data about you from various third parties and public sources including:

  • Directors, shareholders and employees at any business or organisation you are associated with;
  • Brokers, accountants, and insurers;
  • Recruiters and recruitment agencies;
  • IT providers;
  • Credit reference agencies;
  • Service providers (including insurers, for underwriting purposes) to help them carry out their services;
  • Legal and tax advisers and persons in relation to any Enterprise Finance Guarantee Scheme or other loan guarantee scheme application;
  • Any person giving (or potentially giving) a guarantee, indemnity or other commitment to any of the Pulse Companies in relation to this matter;
  • Bankers, financiers or other advisers acting on behalf of any of the Pulse Companies, you or any organisation in relation to this matter;
  • Any person where the Pulse Companies are allowed or required to do so by law;
  • UK Finance, the trade association body of which we are members.

Types of Personal Data

“Personal data” means any information about an individual, held by a data controller, from which the controller can identify a specific, living person. It does not include data about a living person that the controller cannot identify.

Some personal data falls into Special Categories under the UK GDPR and is given greater protection. These include any personal data revealing your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and information about your health, as well as genetic and biometric data. Information about criminal convictions and offences is also treated differently from ordinary personal data under the UK GDPR.

The personal data we collect will depend on the relationship you have with Pulse.

Employees, Contractors and Applicants

If you are an employee of Pulse, someone working with us under a contract for services, or someone who applies for employment or work with us, we will provide you with specific privacy information and ask for your consent to use your personal data. We will also collect the following information on you:

  • Identity Data including first name, last name, title, job title, role or similar identifier, and gender, as well as proof of identity and your right to work in the UK.
  • Contact Data which may include your address, email address and telephone numbers.
  • Financial Data to provide pay, benefits and conduct other financial transactions with you.

Business Contacts and Clients

If you are a business contact, including persons who supply us with goods or services and any contacts at a company or other organisation, and clients to whom we supply our products and services, as well as the customers and debtors of our clients, we may collect:

  • Identity Data including first name, last name, title, job title, role or similar identifier, and gender.
  • Contact Data including your work address, email address and telephone numbers.
  • Financial Data if we supply or purchase goods and services to or from you as an individual (including some sole traders and partnerships), we may record and retain details of those transactions.

Recording of Internal and External Meetings

We may record virtual meetings conducted via Microsoft Teams, including both internal meetings (e.g., staff briefings, project updates) and external meetings (e.g., client consultations, partner collaborations). Recordings are made for purposes such as documentation, training, compliance, and accessibility.

Participants will be notified at the start of any recorded session via an on-screen alert provided by Microsoft Teams. By continuing to participate, attendees acknowledge and consent to the recording.

Recordings may include audio, video, screen sharing, chat messages, and other shared content. These are stored securely within our Microsoft 365 environment (e.g., OneDrive or SharePoint) and are accessible only to authorised personnel. Recordings are retained in accordance with our data retention policy.

Individuals whose personal data is captured in recordings have rights under applicable data protection laws, including the UK GDPR. Requests to access, rectify, or erase such data can be submitted to our Data Protection Compliance Officer.

If You Fail to Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested:

  • We may not be able to best advise you on the funding facility that is applicable to your needs;
  • We may not be able to advise on the terms and conditions that would apply to any funding facility offer;
  • We may not be able to agree, enter into or perform a contract we have or are trying to enter into with you or a person or organisation associated with you. Our client may also be placed in breach of the terms of a finance agreement with us;
  • If you are an employee, contractor or applicant for a position with us, we may not be able to consider your application, provide you with pay or benefits, or administer a contract for services or contract of employment with you.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

What Do We Do With the Information?

We will only use your personal data when the law allows us to. Most commonly, we will use, analyse and assess your personal data in the following circumstances:

  • To provide you with information, products or services that you ask for;
  • To let you know about other products and services that we think you might be interested in (if you have said that you are happy to be contacted in this way);
  • To make financial risk assessments, prevent money laundering, fraud or other wrongdoing;
  • Making payments to you and/or your business;
  • Recovering monies;
  • Training, product and statistical analysis and development of new products;
  • Protecting our interests (including the provision of the information to third parties retained by us for them to conduct their services for us);
  • To make a decision as to whether to extend credit to a client or prospective client, or whether to vary the terms of our agreements with a client;
  • To enter into or negotiate contracts, or to fulfil our legal and regulatory obligations.

In obtaining or storing information about you we may:

  • Store and process information about you including on our computers and in any other way;
  • Search your record at a credit reference or fraud prevention agency of our choice;
  • For the prevention and detection of fraud we may use your IP address to ensure you are located in the UK when signing legal documentation;
  • Monitor and/or record telephone conversations with you for training and/or security purposes;
  • Approach you for market research or direct marketing purposes;
  • Seek and record any further information that we may require from any source, including banks;
  • Transfer information to other members of our group of companies, to our financiers, to associates or persons acting on our behalf, to guarantors or indemnifiers and to businesses providing similar services to those of Pulse.

Automated Decision-Making

In the course of providing our factoring, invoice discounting, bad debt protection and trade finance products, we may use automated processes to assist in assessing creditworthiness, setting credit limits, or evaluating the risk profile of clients, debtors or personal guarantors. These tools support our internal decision-making and are used alongside appropriate human oversight. Where any such process produces a decision that has a legal or similarly significant effect on you, you have the right to:

  • Request that a member of our team reviews the decision;
  • Make representations about the decision; and
  • Obtain an explanation of the basis on which the decision was made.

To exercise any of these rights, please contact our Data Protection Compliance Officer at compliance@pulsefinancelimited.com.

If you do not want your data to be used by us or selected third parties for marketing purposes, please ensure that you select the appropriate option on any of our online forms. You can also notify us at any time if you do not wish your data to be used in this way.

Purposes for Which We Will Use Your Personal Data

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose / Activity
Type of Data
Lawful Basis for Processing

To register you (or your employer or a person or entity to whom you provide services) as a new client.
(a) Identity data

  • (b) Contact data
  • (c) Financial data (for credit purposes) (a) Performance of a contract with you
  • (b) Necessary for our legitimate interests
  • (c) Your consent

To fulfil our contractual obligations to a client, to you or your organisation or to enforce your or your organisation’s obligations to us or to our client, including to:

  • (a) Manage payments, fees and charges
  • (b) Collect and recover money owed to us (a) Identity data
  • (b) Contact data
  • (c) Financial data
  • (d) Transaction data (a) Performance of a contract with you
  • (b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

  • (a) Notifying you about changes to our terms or privacy policy
  • (b) Contacting you about products or services we obtain from or provide to you or your employer (a) Identity data
  • (b) Contact data (a) Performance of a contract with you
  • (b) Necessary to comply with a legal obligation
  • (c) Necessary for our legitimate interests (to keep our records updated and to study how our products/services are used)

To administer and protect our business which may include: financial risk assessment, preventing money laundering, fraud or other wrongdoing; contacting credit reference agencies and making credit related decisions; recovering monies and making payments to you and/or your business.
(a) Identity

  • (b) Contact (a) Necessary for our legitimate interests
  • (b) Necessary to comply with a legal obligation

To administer a contract for services or contract of employment between us — we will provide you with further information about this when we collect information from you and during the course of our relationship.
(a) Identity data

  • (b) Contact data
  • (c) Financial data (a) Performance of a contract with you
  • (b) Necessary for our legitimate interests (to administer the economic relationship between us)
  • (c) Necessary to comply with a legal obligation

If you do not select the appropriate option, but wish to do so subsequently, please contact compliance@pulsefinancelimited.com and we shall change your preference for you.

Disclosure of Your Information

We may have to share your personal data with the parties set out below for the purposes set out in the table above.

  • External third parties as set out in the Glossary;
  • Specific third parties listed in the table above;
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets;
  • A third party we use to host, manage and support our website and provide web chat functionality — they therefore have access to any data that you submit via this website;
  • Carefully selected third-party service providers to support the delivery of our factoring and receivables funding services.

We require all third parties to respect the security of your personal data. We do not normally transfer personal information outside of the United Kingdom, but if we do, we will ensure a similar degree of protection is afforded to it as would be provided under the UK GDPR.

How Long We Keep Information

For more information on how long we store your personal information or the criteria used to determine retention periods, please contact us using the details provided above.

Your Rights

You have a number of rights under data protection law in relation to your personal data. These are summarised below and explained in more detail in the Glossary:

  • Request access to your personal data (subject access request);
  • Request correction of your personal data;
  • Request erasure of your personal data;
  • Object to processing of your personal data;
  • Request restriction of processing your personal data;
  • Request transfer of your personal data;
  • Right to withdraw consent; and
  • Right to make representations about, or request human review of, any automated decision that significantly affects you.

To exercise any of these rights, please contact our Data Protection Compliance Officer at compliance@pulsefinancelimited.com.

Your Right to Make a Data Protection Complaint to Us

If you have a concern about how Pulse Finance Limited has collected, used, stored, shared or otherwise handled your personal data, you have the right to raise a formal data protection complaint directly with us. We take all such complaints seriously and are committed to investigating them thoroughly and fairly.

You can submit a data protection complaint by:

  • Email: compliance@pulsefinancelimited.com
  • Post: Data Protection — Compliance Team, Pulse Finance Limited, The Grosvenor, Basing View, Basingstoke, Hampshire, England, RG21 4HG
  • Telephone: You can express concerns verbally and we will capture details

We will acknowledge your complaint within 30 days of receipt. We will then investigate and respond to you in full without undue delay, keeping you informed of progress throughout. Once our investigation is concluded, we will write to you with our findings and any action we have taken, and we will explain your options if you remain dissatisfied.

Your Right to Complain to the ICO

You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection (www.ico.org.uk, telephone 0303 123 1113). The ICO will generally expect you to have raised the matter with us first, and we would welcome the opportunity to address your concerns directly before any ICO involvement. However, you may contact the ICO at any point if you prefer to do so.

Glossary

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to provide ABL services the best we can. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract.

Comply with a Legal or Regulatory Obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Protecting Your Vital Interests applies where we would otherwise require your consent to use data but you are physically or legally incapable of giving consent, and processing is to protect your interests — for example, to facilitate urgent medical treatment.

Third Parties

External Third Parties

  • Service providers acting as processors based inside and outside the EEA who provide technical, financial, logistical, information technology or other support for our work;
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, insolvency practitioners, and insurers who provide consultancy, banking, legal, insurance and accounting services;
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances;
  • UK Finance, the trade association body of which we are members.

Your Legal Rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.