Last updated: 4 October 2026
1. Who we are
This website is operated by KOULEN & PARTNERS LTD, a company registered in England & Wales (“Koulen & Partners”, “we”, “us”). We are the controller of the personal data described in this policy.
If you have any questions about this policy or how we handle your data, contact us at maxwell@koulenandpartners.co.uk.
2. Who this policy applies to
We provide finance broking services to businesses. This policy covers the personal data of people who use our website or contact us — typically directors, shareholders, guarantors and staff of borrowing companies, introducers and other professionals.
3. The information we collect
Information you give us
- Contact details: name, company, job title, email address and phone number.
- Details of the property or project and the finance required, such as addresses, values, loan amounts, existing borrowing, planning position and track record.
- Any documents you choose to upload or send to us, and anything you tell us in messages.
- If we go on to act for you: identity and verification information about directors, shareholders and guarantors, and financial information that lenders require.
Information collected automatically
- Technical information processed by our hosting provider when you visit the site, such as IP address, browser type and the pages requested, used to deliver and secure the website.
- Your cookie choice, stored in your browser. Analytics information only if you accept analytics cookies — see our Cookie Policy.
Information from others
We may receive information about you from introducers you have asked to refer you, from lenders and valuers involved in your application, and from public sources such as Companies House and HM Land Registry.
4. How our website forms work
When you submit a form on this website, the information is sent securely to our email inbox. The website itself does not keep a copy in a database. Emails are delivered on our behalf by an email service provider acting as our processor.
5. Why we use your information and our lawful bases
| Purpose | Lawful basis |
|---|---|
| Responding to enquiries and discussing your finance requirements | Legitimate interests (responding to business enquiries); steps taken at your request before entering into a contract |
| Arranging finance, including presenting your case to lenders with your agreement | Performance of a contract with you or the company you represent; legitimate interests |
| Identity checks, fraud prevention and anti-money-laundering obligations | Legal obligation; legitimate interests in preventing fraud |
| Keeping business records and handling complaints or legal claims | Legal obligation; legitimate interests |
| Working with introducers and professional partners | Legitimate interests |
| Website analytics (only if you accept analytics cookies) | Consent, which you can withdraw at any time |
Where we rely on legitimate interests, we have considered your interests and rights and concluded that the processing is proportionate. You can ask us for more detail.
6. Who we share information with
- Lenders, funders and their valuers and solicitors — only in connection with finance you have asked us to arrange.
- Service providers who support our business, such as website hosting, email delivery and IT providers, acting on our instructions.
- Professional advisers such as our accountants, lawyers and insurers.
- Introducers who referred you, to keep them updated — only where you have agreed.
- Regulators, law enforcement or other authorities where we are required to by law.
We do not sell personal data.
7. International transfers
Some of our service providers, such as our hosting and email delivery providers, may process data outside the UK, including in the United States. Where this happens we rely on appropriate safeguards recognised under UK data protection law, such as UK adequacy regulations or the International Data Transfer Agreement or Addendum.
8. How long we keep information
We keep enquiries that do not proceed for as long as is reasonably needed to follow them up, and then delete them. Where we act for you, we keep records for as long as needed to provide our services and afterwards for the periods required by law and for regulatory, tax and legal-claims purposes. Specific retention periods are available on request.
9. Your rights
Under UK data protection law you have the right to:
- access the personal data we hold about you;
- have inaccurate data corrected;
- have data erased in certain circumstances;
- restrict or object to our processing in certain circumstances, including objecting to processing based on legitimate interests;
- data portability, where processing is based on consent or contract and carried out by automated means;
- withdraw consent at any time, where we rely on consent.
To exercise any of these rights, contact maxwell@koulenandpartners.co.uk. We will respond within one month, which may be extended in some cases as the law allows. We do not make decisions about you based solely on automated processing.
10. Security
The website uses encrypted connections (HTTPS). We restrict access to personal data to those who need it, and require our service providers to protect it. Please do not send passports, bank statements or other identity documents through the website forms; we will tell you how to provide them securely if needed.
11. Complaints
If you are unhappy with how we have handled your data, please contact us first. You also have the right to complain to the Information Commissioner’s Office (ICO) at ico.org.uk or on 0303 123 1113.
12. Changes to this policy
We may update this policy from time to time. The date at the top shows when it was last changed.