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Who we are

Synergy Commercial Finance Limited is an independent commercial finance broker. We are committed to protecting your personal data and ensuring transparency in how we use it.

Data Controller: Synergy Commercial Finance Limited

Address: Greenbank Court, Challenge Way, Greenbank Business Park, Blackburn BB1 5QB

AFS Compliance Ltd acts as the principal firm under the Financial Conduct Authority (FCA) Appointed Representative (AR) regime. We are responsible for overseeing compliance through a network of Appointed Representatives (ARs) who operate under our regulatory permissions.

We provide access to our bespoke compliance platform, BIPS, which is used to process finance applications, enforce compliance workflows, and manage deal flow securely. BIPS logs user activity, automates regulatory checks, and ensures consistent adherence to legal and financial standards.

As Principal, we are the data controller for activities related to regulatory oversight, AML, monitoring, and platform performance. In some cases, we act as joint controllers or processors in coordination with ARs and lenders. Joint controller roles are governed by the Data Use and Access Act 2025 (DUAA), which sets out mandatory joint-controller responsibilities, record-keeping, and liability sharing.

Email: gdpr@afsuk.com

Our Data Protection Officer (DPO) can be contacted at the above email for any questions about this notice or your rights.

What Personal Data We Collect

We may collect and process the following categories of personal data:

Type Category
Identity & Contact Data Name, date of birth, address, phone numbers, email address, ID documentation (passport, driving license)
Financial & Credit Data Income, expenditure, credit history, employment details, Bank details, financial commitments, and credit reports
Transactional Data Details about the finance products or services you’ve engaged with
Usage Data IP address, browser type, interaction with our website or services
Special Category Data Health information (e.g., if disclosed as part of accessibility or vulnerability declarations)
Only collected with explicit consent

BIPS, our compliance platform, automatically logs deal-related activity, time-stamps key compliance events, and tracks access to sensitive data. These logs are used for regulatory supervision and internal auditing.

How We Collect Your Data

We collect data:

Why We Process Your Data (Purposes & Lawful Bases)

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

  1. Consent: the individual has given clear consent for you to process their personal data for a specific purpose
  2. Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract
  3. Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations)
  4. Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law
  5. Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)
Purpose Legal Basis Explanation
To assess and arrange finance products Contractual necessity (Art. 6(1)(b)) To take steps at your request prior to entering a finance agreement
To carry out credit and fraud checks Legitimate Interests (Art. 6(1)(f))

Contractual necessity (Art. 6(1)(b))

These checks are required by financial crime laws and to assess your suitability for finance.

To take steps at your request prior to entering a finance agreement.

To communicate with you about your application or finance options  Contractual necessity (Art. 6(1)(b)) & Legitimate Interests (Art. 6(1)(f)) To ensure clear service delivery and client care
To refer your application to lenders or franchisee brokers Legitimate Interests (Art. 6(1)(f)) & Contractual necessity (Art. 6(1)(b)) To fulfil your finance enquiry effectively
To meet legal and regulatory obligations Legal obligation (Art. 6(1)(c)) To comply with UK financial and data protection laws
To monitor service quality and handle complaints Legitimate interests (Art. 6(1)(f)) To improve service and resolve disputes
Marketing communications Consent (Art. 6(1)(a)) We will only send marketing communications with your explicit opt-in
Processing special category data (e.g., health) Explicit Consent (Art. 9(2)(a)) Only processed if freely given by you for specific support needs
To monitor compliance via the BIPS platform Legal obligation (Art. 6(1)(c)) & Legitimate interests (Art. 6(1)(f)) To ensure ARs meet FCA regulatory standards and prevent misuse of the platform or financial crime exposure

Credit Checks:

To facilitate the performance of the contract with you, Synergy Commercial Finance Limited may need to conduct credit checks, either on our behalf or directly through a lender.

By continuing your application for credit, you acknowledge and consent that credit checks may be carried out, which could impact your credit file.

By continuing your application for credit, you are processed under Legitimate Interests and/or Legal Obligation, and in line with DUAA this does not rely on consent. Credit checks may impact your credit file.

Where we rely on Legitimate Interests, we have completed a Legitimate Interests Assessment (LIA). A summary of these assessments is available upon request.

Who We Share Your Data With

We may share your data with the following third parties, where appropriate:

All sharing with lenders, ARs and product providers is governed by the DUAA, which sets out controller responsibilities and safeguards. Under DUAA joint controller provisions, we and relevant lenders/ARs must ensure you are told which party to contact for exercising your data rights, who is primarily responsible for complaints, and how liability is apportioned.

Automated Decision-Making and Profiling

Some lenders may use automated decision-making (e.g., credit scoring) to assess your eligibility. You will be informed directly if this occurs and can request human intervention or express your point of view.

We may use limited profiling to help match you with finance providers that best suit your circumstances or business needs. This involves evaluating financial information and preferences to support product suitability decisions.

We do not make decisions solely based on automated profiling that produce legal or similarly significant effects. Profiling activities are carried out under Legitimate Interests in compliance with the DUAA. You have the right to object and request human review.

International Transfers

Your data is primarily stored in the UK. If it must be transferred outside the UK/EEA, we ensure:

How We Protect Your Data

We take the protection of your personal data seriously. We use a combination of technical and organisational measures to safeguard it. These include:

Data Retention

We retain personal data for up to 6 years after your case is closed, in line with FCA requirements and to support legal claims or audits. Specific retention periods may vary depending on the data type:

In some cases, we may retain data longer if legally required (e.g., under HMRC rules).
Retention periods are reviewed for DUAA compliance, particularly in relation to credit check data.

Your Rights

You have the following rights under the UK GDPR:

To exercise any of these rights, contact: gdpr@afsuk.com

If you’re unsatisfied with our response, you can complain to the Information Commissioner’s Office (ICO): www.ico.org.uk | Tel: 0303 123 1113

For questions related to your specific finance application, please contact your broker directly. For questions about how your data is processed on the BIPS platform or about AFS Compliance’s role, contact gdpr@afsuk.com.

Cookies and Online Tracking

We use cookies and similar tracking tools to:

We use cookies and tracking tools in compliance with the UK Privacy and Electronic Communications Regulations (PECR) and UK GDPR. Where required, we request your consent before placing non-essential cookies.

You can manage cookie preferences through our Cookie Policy or browser settings.

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