Logo
Privacy Policy of Gemba Finance LTD
Effective as of 10 April 2026

PRIVACY POLICY

Gemba Finance Ltd

Introduction

Welcome to the Gemba Finance Ltd privacy policy.

Gemba Finance Ltd respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Please also use the Glossary (section 18) to understand the meaning of some of the terms used in this privacy policy.

1. Important Information and Who We Are

Purpose of This Privacy Policy

This privacy policy aims to give you information on how Gemba Finance Ltd collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a service.

This website is not intended for children under the age of 18 and we do not knowingly collect data relating to children. If you are under the age of 18, please do not apply for an account with us, provide any personal information to our website or use our website in any other way.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Gemba Finance Ltd is the controller and responsible for this website. Gemba Finance Ltd is registered in England and Wales under company registration number 11040011. Registered office: Level 39, One Canada Square, Canary Wharf, London, England, E14 5AB. Gemba Finance Ltd is the provider of payment services under the trading name Gemba.

Gemba Finance Ltd is authorised by the Financial Conduct Authority (FCA) under the Payment Services Regulations 2017. FCA firm reference number: 804853.

Gemba Finance Ltd is registered with the Information Commissioner’s Office (ICO). ICO registration number: ZB321826.

Gemba Finance Ltd has a branch in Latvia: Gemba Finance Ltd filiale Latvia, registered address: Rīga, Balasta dambis 80A, LV-1048, which provides administrative support services only.

This privacy policy is issued on behalf of the Gemba Finance Ltd Group, so when we mention “Gemba Finance Ltd”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Gemba Finance Ltd Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a service with us.

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact Gemba Finance Ltd using the details set out below.

Contact Details

Gemba Finance Ltd

Address: Level 39, One Canada Square, Canary Wharf, London, England, E14 5AB

Email: dataprotection@ge.mba

We have not appointed a Data Protection Officer as we do not consider that our processing operations require one under Article 37 of the UK GDPR. If this position changes, we will update this privacy policy accordingly.

In the event of a personal data breach or suspected personal data breach, we encourage you to contact Gemba promptly.

With regard to data protection issues in the UK, you 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). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Complaints About Our Data Processing

If you wish to raise a complaint about how we have handled your personal data, you can contact us using the details above and we will investigate the matter. We will acknowledge your complaint within 30 days and respond to it without undue delay, providing you with the outcome and any steps we have taken or propose to take. You may also submit a complaint electronically via our website.

If you are not satisfied with our response, you have the right to lodge a complaint with the ICO at any time.

EU Representative

If you are located in the European Union, you can refer privacy-related questions to our EU representative appointed under Article 27 of the EU General Data Protection Regulation (EU GDPR):

SIA Datu Aizsardzības pakalpojumi

Reg. No. 40203086361

Email: info@fpda.lv

Website: www.fpda.lv

With regard to data protection issues in Latvia, you have the right to make a complaint at any time to the Data State Inspectorate, the Latvian supervisory authority (https://www.dvi.gov.lv). We would, however, appreciate the chance to deal with your concerns before you approach the Data State Inspectorate, so please contact us in the first instance.

Changes to This Privacy Policy and Your Duty to Inform Us of Changes

We keep our privacy policy under regular review. This version was last updated on 10 April 2026.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

2.1. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, title, gender, nationality, identity document details, date of birth, place of birth, a visual representation of the face and a copy of the supporting document as a basis for the information on the affiliation to the address, and information regarding your employment.

Contact Data includes billing address, email address and telephone numbers.

Financial Data includes financial status, bank account details, taxpayer’s country and number, and information on the reasons for opening the account.

Transaction Data includes details about payments to and from you and other details of services you have purchased from us.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

Profile Data includes your username and password, your interests, preferences, feedback and survey responses.

Usage Data includes information about how you use our website and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

2.2. If you are a corporate entity, we may also collect your registered name, registered office address, memorandum of association, articles of association, list of current shareholders, list of current directors, annual return, identification and proof of address of beneficial owners, directors and any power of attorney.

2.3. We may collect information about you contained in any documents you provide to us for the purposes of verifying and processing your application for an account with us.

2.4. We may collect information about your transactions and your activities when you apply for an account with us and carry out a transaction using our services. Such information may include without limitation the identity of the other party to the transaction, their location and the currency and amount of the payment.

2.5. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

2.6. We do not routinely collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We may process information about criminal convictions and offences where this is necessary for the purposes of preventing fraud and money laundering, or as otherwise required by law. Any such processing is carried out under Schedule 1, Part 1, paragraph 10 of the Data Protection Act 2018 (preventing or detecting unlawful acts) and in accordance with an appropriate policy document as required by Schedule 1, Part 4 of that Act.

3. If You Fail to Provide Personal Data

3.1. 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 perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

4. How Is Your Personal Data Collected?

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

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by our web and mobile application software, post, email or via the messaging forms on our website. This includes personal data you provide when you:

  • Xopen an account with us;
  • Xuse the services made available on our web and mobile application software;
  • Xenter a competition, promotion or survey;
  • Xrequest marketing to be sent to you; or
  • Xgive us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. With regard to each of your visits to our website, we may automatically collect the following:

  • Xtechnical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • Xinformation about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time);
  • Xproducts you viewed or searched for;
  • Xpage response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

  • Xanalytics providers such as Google;
  • Xadvertising networks such as LinkedIn and Facebook;
  • Xsearch information providers such as Google AdWords;
  • XIdentity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK;
  • Xpublicly available UK government sanction lists; and
  • Xcredit reference agencies.

5. How We Use Your Personal Data

5.1. 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:

  • XWhere we need to perform the contract we are about to enter into or have entered into with you.
  • XWhere it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • XWhere we need to comply with a legal obligation.
  • XWhere you have given your consent to the processing for a specific purpose.
  • XWhere processing is necessary for a recognised legitimate interest, as defined by the Data (Use and Access) Act 2025, such as the prevention or detection of crime (see section 18, Glossary, for further details).

See the Glossary (section 18) to find out more about the types of lawful basis that we will rely on to process your personal data.

5.2. Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

5.3. We are required under the Proceeds of Crime Act 2002, the Terrorism Act 2000, and the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended) to keep records about you and your transactions.

6. Purposes for Which We Will Use Your Personal Data

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

6.2. 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 including basis of legitimate interest

To administer and process your application for services with us

(a) Identity (b) Contact

Performance of a contract with you

To administer and maintain our customer accounts and records including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us

(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications

(a) Performance of a contract with you (b) Necessary for our legitimate interests

To provide our services to you and ensure secure transaction processing including: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey

(a) Identity (b) Contact (c) Profile (d) Marketing and Communications

(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 customers use our services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications

Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity (b) Contact (c) Technical

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

To use data analytics to improve our website, services, marketing, customer relationships and experiences

(a) Technical (b) Usage

Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about services that may be of interest to you

(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications

Necessary for our legitimate interests (to develop our services and grow our business)

To comply with our obligations under anti-money laundering, counter-terrorist financing, sanctions, fraud prevention and other applicable laws and regulations

(a) Identity (b) Contact (c) Financial (d) Transaction

(a) Necessary to comply with a legal obligation (b) Recognised legitimate interest (prevention or detection of crime)

To send you direct marketing communications about our services (where you have consented)

(a) Identity (b) Contact (c) Profile (d) Marketing and Communications

Consent

To conduct internal research, statistical analysis and customer service monitoring

(a) Identity (b) Technical (c) Usage (d) Profile

Necessary for our legitimate interests (to improve our services and internal operations)

To screen your application and monitor your transactions using automated systems for fraud prevention, anti-money laundering and sanctions compliance (see section 7 for further details)

(a) Identity (b) Contact (c) Financial (d) Transaction

(a) Necessary to comply with a legal obligation (b) Recognised legitimate interest (prevention or detection of crime)

6.3. See the Glossary (section 18) to find out more about the types of lawful basis that we will rely on to process your personal data.

7. Profiling and Automated Decision-Making

7.1. As a provider of payment services, we use automated systems and profiling in certain circumstances. This section explains what profiling and automated decision-making we carry out, the logic involved, and the significance and consequences for you.

What is profiling?

Profiling means any form of automated processing of personal data that involves using your personal data to evaluate certain personal aspects about you. We use profiling to help us make decisions about the services we provide to you and to meet our legal and regulatory obligations.

How we use profiling and automated decision-making

7.2. We may use profiling and automated systems in the following ways:

Anti-money laundering and sanctions screening. When you apply to open an account with us and on an ongoing basis, we screen your Identity and Financial Data against UK and international sanctions lists, politically exposed persons (PEP) databases and other watchlists. This screening is carried out using automated systems and is necessary to comply with our legal obligations under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended) and the Sanctions and Anti-Money Laundering Act 2018.

Fraud detection and transaction monitoring. We monitor your Transaction Data using automated rules and models to detect unusual or potentially fraudulent activity. These systems analyse patterns such as transaction amounts, frequency, geographic location and counterparty information. A transaction or account may be flagged for further review where it falls outside expected parameters.

Customer risk assessment. When you apply for an account, we may use automated tools to assess the level of risk associated with providing services to you, based on factors including your identity verification results, source of funds information, geographic risk and transaction profile.

The logic involved

7.3. Our automated systems apply rules and algorithms based on regulatory requirements, industry standards and our own risk management policies. These systems compare your data against known risk indicators and thresholds. Where a system identifies a potential concern, it generates an alert for review.

Significance and consequences for you

7.4. In most cases, automated screening and profiling is used to support rather than replace human decision-making. However, automated processing may result in:

a delay in the processing of your application or a transaction while further checks are carried out;

a request for additional information or documentation from you;

a decision to decline your application for an account or to restrict or terminate your access to our services; or

the filing of a suspicious activity report with the relevant authorities (in which case we will not be able to inform you of this).

Your rights

7.5. Where a decision is made about you based solely on automated processing (including profiling) which produces legal effects concerning you or similarly significantly affects you, you have the right to be informed about the decision, to make representations about it, to challenge the decision, and to obtain human intervention. See section 15.6 for further details on how to exercise these rights.

7.6. If you have any questions about how we use profiling or automated decision-making, please contact us at dataprotection@ge.mba.

8. Marketing

8.1. Subject to your prior consent, we may use your data to contact you for market research purposes and to provide you with information about our services, offers and promotions which may be of interest to you. If we do so, we will contact you by email. If you do not want us to use your data in this way, please contact us using the contact details provided or use the unsubscribe link in any marketing email.

8.2. Your information may be used by us for the purpose of research, statistical analysis and internal customer service monitoring. We rely on our legitimate interests as the lawful basis for this processing (see the table in section 6 above).

9. Third Parties

9.1. We use certain processors in the general running of our business and to assist us in providing services to our clients, including in connection with our website, web and mobile application software and the services provided through them. A processor is a third-party service provider or data processor engaged by us who has or potentially will have access to, or will process, personal data. If you would like to know which processors have or have had access to your personal data, please contact us using the contact details provided.

10. Cookies

10.1. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a more personalised experience when you browse our website and also allows us to improve our website.

10.2. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

10.3. In accordance with the Privacy and Electronic Communications Regulations 2003 (PECR) as amended by the Data (Use and Access) Act 2025, we will obtain your consent before placing non-essential cookies on your device. Certain low-risk cookies (such as those used solely for analytics or to improve the functionality of our website) may be placed on an opt-out basis where permitted by the amended PECR. We will always provide you with clear information about such cookies and how to opt out.

11. Disclosures of Your Personal Data

11.1. We may share your personal data with the parties set out below for the purposes set out in the table in section 6 above:

  • XInternal Third Parties as set out in the Glossary (section 18).
  • XExternal Third Parties as set out in the Glossary (section 18).
  • XThird parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

11.2. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

11.3. We are required by statute to make a disclosure where we know or suspect that a transaction involves money laundering or terrorist financing. Where we are required to make a disclosure in relation to one of your transactions, we will not be able to inform you about the disclosure or our reasons for making it.

11.4. We may approve customer requests regarding disclosure of their information to third parties after checking that the applicant is the person concerned. Additionally, in the case of inaccurate information that we know about, we will apply the necessary changes to it.

12. International Data Transfers

12.1. Where we share your personal data within the Gemba Finance Ltd Group, this may involve transferring your data outside the UK. We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are set out in intra-group data processing agreements. For further details, see the ICO guidance on international data transfers.

12.2. Where we engage with a supplier or agent, this may involve transferring your data outside the UK on our behalf. We will undertake due diligence, monitoring and assurance activities to ensure that the personal data is appropriately protected, and contractual clauses will be agreed between the parties to ensure that data protection and confidentiality is maintained.

12.3. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data under UK data protection law, or where appropriate safeguards are in place. For further details, see the ICO guidance on international data transfers.

12.4. Where we use certain service providers, we may use transfer mechanisms approved under UK data protection law, including the UK International Data Transfer Agreement (IDTA) and/or the UK Addendum to the EU Standard Contractual Clauses. For further details, see the ICO guidance on international data transfer agreements.

13. Keeping Information Up to Date and Secure

13.1. If any of the information that you have provided to us changes, for example, if you change your email address or other contact details, or if you wish to close your account with us, please update your account details on our website or, alternatively, contact us using the contact details provided.

13.2. Where we have given you (or where you have chosen) a username and password which enable you to access certain parts of our website, you are responsible for keeping your username and password confidential. We ask you not to share this information with anyone.

13.3. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

13.4. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

14. Data Retention

14.1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

14.2. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

14.3. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for a minimum period as required by applicable law, including anti-money laundering legislation.

14.4. In some circumstances you can ask us to delete your data: see section 15 (Your Legal Rights) below for further information.

14.5. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

15. Your Legal Rights

15.1. Under UK data protection legislation (including the UK GDPR, the Data Protection Act 2018 and the Data (Use and Access) Act 2025), you have certain rights in relation to the personal data that we hold about you. These rights include the rights set out below:

Request access to your personal data (commonly known as a “data subject access request”).

Request rectification of your personal data.

Request erasure of your personal data.

Object to processing of your personal data.

Request restriction of processing of your personal data.

Request the transfer of your personal data (data portability).

Right to withdraw consent.

Rights in relation to automated decision-making (see section 15.6 below).

Right to complain about our processing of your personal data (see section 1, Complaints About Our Data Processing).

15.2. If you wish to exercise any of the rights set out above, please contact us by sending an email to dataprotection@ge.mba or by submitting an application to Gemba’s registered office.

15.3. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

15.4. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

15.5. You are entitled to require a correction of errors in the personal information held about you. If we disagree that information is inaccurate, you are entitled to apply to the court for an order that such erroneous information is rectified, blocked, destroyed, or erased.

15.6. Where a decision is made about you based solely on automated processing (including profiling) which produces legal effects concerning you or similarly significantly affects you, you have the right to be informed about the decision, to make representations about it, to challenge the decision, and to obtain human intervention. We will notify you where any such automated decision-making is used and provide you with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing. See section 7 for details of how we use profiling and automated decision-making.

15.7. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. If necessary, that period may be extended by a further two months, taking into account the complexity and number of requests. We will inform you of any such extension within one month of receipt of your request. Where we reasonably require clarification from you in order to respond to your request, the response period will be paused until you provide the information needed.

16. Your Right to Withdraw Consent

16.1. Where we rely on your consent as a lawful basis for processing your personal data, you have the right to withdraw that consent at any time. To ensure that the most recent information about the processing of your personal data is always available to you, we will make sure that this privacy policy is reviewed and updated on a regular basis. We encourage you to read the latest version of this privacy policy on our website from time to time.

16.2. You may withdraw consent at any time by sending an email to dataprotection@ge.mba or by submitting an application to Gemba’s registered office. No further data processing based on consent for the specific purpose will be carried out following such withdrawal.

16.3. Withdrawal of consent will not affect the lawfulness of any processing carried out before the withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.

17. Applicable Law

17.1. This privacy policy and the processing of your personal data are governed by the laws of England and Wales, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the Data (Use and Access) Act 2025, and the Privacy and Electronic Communications Regulations 2003 (PECR).

17.2. Nothing in this privacy policy is intended to limit or exclude any rights you may have under applicable data protection legislation, including your right to lodge a complaint with the Information Commissioner’s Office or to seek a judicial remedy under applicable law.

17.3. If you are located in the European Economic Area, your rights under the EU General Data Protection Regulation (including your right to bring proceedings in the courts of your habitual residence) are not affected by this privacy policy.

18. Glossary

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Recognised Legitimate Interest means a lawful basis introduced by the Data (Use and Access) Act 2025 under which personal data may be processed where it is necessary for certain defined purposes, including the prevention or detection of crime, safeguarding vulnerable individuals, or responding to emergencies. Where we rely on this basis, there is no requirement for us to carry out the standard balancing test, although we must still comply with the other principles of UK data protection legislation and your right to object.

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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Consent means where you have given us clear, affirmative indication of your agreement to the processing of your personal data for a specific purpose.

Third Parties

Internal Third Parties

Other companies in the Gemba Finance Ltd Group acting as processors and who are based in Latvia and provide administrative support services.

External Third Parties

Service providers acting as processors who provide IT and system administration services.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, the FCA and other regulators and authorities acting as independent controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

Fraud prevention agencies.

Credit reference agencies.

Other financial institutions and third parties involved in the execution of transactions.

Supervisory authorities acting on the basis of written requests or duties stipulated by applicable legislation (including courts, investigation bodies, the prosecutor’s office, operational entities, sworn bailiffs, notaries and insolvency administrators).

Participants of international payment systems.

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 rectification 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. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with applicable law. Note, however, 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your 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:

  • Xif you want us to establish the data’s accuracy;
  • Xwhere our use of the data is unlawful but you do not want us to erase it;
  • Xwhere 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
  • Xyou have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request data portability. This allows you to obtain and reuse your personal data for your own purposes across different services. 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. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Rights in relation to automated decision-making. Where a decision with legal or similarly significant effects is made about you based solely on automated processing, you have the right to be informed about the decision, to make representations, to challenge the decision, and to obtain human intervention. See section 15.6 for further details.