Privacy Policy

1. Introduction

This Privacy Policy explains how Lendermarket Limited (“Lendermarket”, “we”, “us”, “our”) collects, uses, discloses and protects your personal data (“Data”) when you visit or use www.lendermarket.com (the “Site”) or access our investment platform and related services.
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We are committed to processing your Data lawfully, fairly and transparently in accordance with:
• General Data Protection Regulation (EU) 2016/679 (“GDPR”)
• Data Protection Act 2018 (Ireland)
• Swiss Federal Act on Data Protection (FADP)
• Crowdfunding Regulation (EU) 2020/1503
• Anti-Money Laundering Directives (AMLD5/AMLD6)
• Any other applicable data protection legislation (“Data Protection Legislation”)
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This Privacy Policy should be read together with our Cookie Policy and any other privacy notices we provide on specific occasions.
The Site and our services are not intended for children, and we do not knowingly collect data relating to children.
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2. Application of privacy policy

This Privacy Policy applies to your use of the Site, our investment platform, and any related services. It describes the data we collect, how we use it, and your rights.
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This Privacy Policy supplements other notices and is not intended to override them.
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3. Identity of the data controller

The Data Controller responsible for your Data is:

Lendermarket Limited
77 Sir John Rogerson’s Quay, Block C, Grand Canal Docklands, Dublin 2, D02 VK60, Ireland
Company Number: 585178

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4. Contact information for the data protection officer

We have appointed a Data Protection Officer who oversees our compliance with Data Protection Legislation.
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DPO: Tauri Jaanson
Email: dpo@lendermarket.com
Phone: +353 16 917 618

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5. Data we collect

We collect Data directly from you, automatically through your use of the Site, and from third-party sources such as KYC/AML providers.

5.1 Personal Identification Data

• First and last name
• Date of birth
• National identity number or equivalent
• Country and tax residency
• Contact details (email, phone, address)

5.2 Legal Entity Investor Data

• Entity name, registration number, legal address
• Country and tax residency
• Bank details
• Representative details
• Beneficial ownership information (>25%)

5.3 Financial and Transactional Data

• Deposits, withdrawals, payments
• Investment activity and portfolio data
• Account balances and transaction history

5.4 KYC/AML and Regulatory Data

• Identity documents (passport, ID card, proof of address)
• Sanctions screening results
• Appropriateness and suitability assessments
• Investor categorisation under the Crowdfunding Regulation

5.5 Technical and Device Data
Collected automatically via cookies and similar technologies:

• IP address
• Browser type and version
• Device identifiers
• Operating system
• Session logs and clickstream data
• Consent ID from Usercentrics CMP

5.6 Communication and Interaction Data

• Information submitted via forms
• Customer support interactions
• Meeting notes (if applicable)

5.7 We Do Not Collect

• Special categories of personal data
• Criminal conviction data (unless required by AML law)

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6. How we use your data

We process your Data for the following purposes:

6.1 To Provide and Manage Your Account

• Registering and maintaining your account
• Enabling secure login
• Executing investments and processing transactions

6.2 To Comply With Legal and Regulatory Obligations
Including obligations under:

• AMLD5/AMLD6
• Crowdfunding Regulation
• Tax reporting laws
• Record-keeping requirements

6.3 To Ensure Platform Security and Prevent Fraud

• Monitoring access to digital channels
• Detecting suspicious activity
• Preventing unauthorised access
• Ensuring information security

6.4 To Improve Our Services

• System testing and performance monitoring
• Staff training
• Quality control
• Analytics and service optimisation

6.5 To Communicate With You

• Responding to enquiries
• Providing account updates
• Notifying you of changes to our services or policies

6.6 Marketing (With Your Consent)

• Sending newsletters and offers
• Personalising marketing content

You may withdraw consent at any time.

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7. Legal Bases for Processing

We rely on the following legal bases:

7.1 Contract (Art. 6(1)(b) GDPR)
To provide our services, manage your account, and execute investments.

7.2 Legal Obligation (Art. 6(1)(c) GDPR)
To comply with obligations under:

• AMLD5/AMLD6
• Crowdfunding Regulation
• Tax and accounting laws
• Regulatory reporting and record-keeping

7.3 Legitimate Interests (Art. 6(1)(f) GDPR)
For purposes such as:

• Fraud prevention and platform security
• Service improvement and analytics
• Protecting our rights and ensuring business continuity

We balance these interests against your rights and freedoms.

7.4 Consent (Art. 6(1)(a) GDPR)
For:

• Marketing communications
• Non-essential cookies
• Optional information you provide voluntarily

You may withdraw consent at any time.

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8. Disclosure of your data

We treat your data as confidential. We share it only when necessary and in accordance with Data Protection Legislation.

8.1 Service Providers (Processors)
We use carefully selected third-party providers for:

• KYC/AML verification
• Payment processing
• Cloud hosting and IT infrastructure
• Analytics and consent management
• Fraud prevention and security
• Communications and customer support

All processors are bound by written contracts requiring confidentiality, security, and compliance with international transfer rules.

8.2 Controller-to-Controller Disclosures
In certain cases, we may share data with:

• Loan originator partners
• Regulators and authorities
• Financial institutions

These parties act as independent Data Controllers and have their own privacy notices.

8.3 Legal Requirements
We may disclose data where required to:

• Comply with law or legal process
• Protect our rights or property
• Protect the safety of users or the public

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9. International transfers

Where data is transferred outside the EEA, UK, or Switzerland, we ensure appropriate safeguards, including:

• 2021 Standard Contractual Clauses (SCCs)
• Transfer Impact Assessments (TIAs)
• Additional technical and organisational measures where required

You may request a copy of the relevant safeguards.

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10. Data retention

We retain data only for as long as necessary for the purposes for which it was collected.

Typical retention periods:

• KYC/AML records: 5–10 years
• Transactional and investment data: 10 years
• Marketing data: until consent is withdrawn
• Technical logs: 6–24 months

Retention periods may vary depending on legal, regulatory, and operational requirements.

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11. Links to other websites

Our Site may contain links to third-party websites. We are not responsible for their privacy practices. You should review their privacy policies before providing any data.

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12. Security

We implement appropriate technical and organisational measures, including:

• Multi-factor authentication
• Encryption in transit and at rest
• Access controls and role-based permissions
• Continuous monitoring and logging
• Regular penetration testing
• Vendor due diligence
• Incident response and breach notification procedures (GDPR Art. 33/34)

No system is completely secure, but we continuously improve our security measures.

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13. Your rights

You have the following rights under GDPR:

• Access to your data
• Rectification of inaccurate data
• Erasure (“right to be forgotten”)
• Restriction of processing
• Data portability
• Objection to processing based on legitimate interests
• Objection to direct marketing
• Withdrawal of consent
• Right to lodge a complaint with any EU supervisory authority, including the Irish DPC

To exercise your rights, contact our DPO at dpo@lendermarket.com.

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14. Complaints

If you are unhappy with how we process your data, please contact our DPO.
You may also contact the Data Protection Commission (Ireland):

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E-mail: info@dataprotection.ie
‍Telephone: +353 (0)761 104 800‍
Postal Address: Canal House, Station Road, Portarlington, Co. Laois, R32 AP23.

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15. Changes to our privacy policy

We may update this Privacy Policy from time to time. Material changes will be communicated to you. The latest version will always be available on our site.

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16. Customer Support

For general support queries, you may contact us at support@lendermarket.com.
Support is available Monday to Friday, 09:00–17:00 (CET).