PRIVACY POLICY

Polar Krush

PRIVACY POLICY

What is a Privacy Policy?

A Privacy Policy is a statement by Polar Krush to clients, our Associates and the public about how we collect, use, retain and disclose the personal information which we hold. It is sometimes also referred to as a Privacy Statement, Fair Processing Statement or Privacy Notice. This Privacy Policy is part of our commitment to ensure that we process your personal information/data fairly and lawfully.

Why have a Privacy Policy?

Polar Krush recognises the importance of protecting personal and confidential information in all that we do, and we take care to meet our legal and regulatory duties. This policy is one of the ways in which we can demonstrate our commitment to being transparent and open. This policy also explains what rights you have to control how we use your information.

Privacy Statement

For the purposes of the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018, the Data Controller is NICC Ltd t/a The Polar Krush Group, Company Registration Number 2892944 (collectively referred to as “Polar Krush”, “we”, “us” or “our” in this privacy statement).

Polar Krush is registered as a Data Controller with the UK Information Commissioner’s Office (“ICO”), registration number ZA054600.

We are committed to safeguarding the privacy of our website visitors, clients, applicants and business contacts. During the course of your engagement with Polar Krush, we may ask you to provide us with personal information to enable us to communicate with you, provide our services, assess applications, comply with legal obligations and manage our business relationship with you. This information is referred to as “Personal Data”.

This statement explains how we use your Personal Data, the lawful basis upon which we process it, how long we retain it and the rights you have in relation to your Personal Data.

Data Protection Contact
If you have any questions regarding this Privacy Policy or wish to exercise any of your data protection rights, please contact our Data Protection Officer (or Privacy Team where a formal DPO appointment is not required) at: dpo@polarkrush.co.uk

Personal Data

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:

“Any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly…”

We may ask for or hold personal information including:

• Name
• Postal address
• Email address
• Telephone number
• Employment details
• Identity verification information
• Credit and affordability information where relevant
• Website usage information
• Correspondence and communications with us

This website collects and uses personal information for the following reasons:

SITE VISITOR TRACKING

Third Party Processor: Google Analytics

Data Collected:

  • Usage data
  • Cookie identifiers
  • Device information
  • IP address information
  • Website interaction data

Google Privacy Policy:
https://policies.google.com/privacy

This site uses Google Analytics to monitor how users interact with our website. This information helps us understand visitor behaviour and improve our website and services.

Google Analytics may process information that constitutes personal data under UK GDPR, including online identifiers and IP address information. We do not use this information to directly identify individual visitors.

Where required by law, analytics cookies will only be placed on your device following your consent. You may withdraw your consent at any time through our cookie preferences settings or browser controls.

For more information, please refer to our Cookie Policy.

CONTACT FORMS & EMAILS

Data Collected:

  • Name
  • Address
  • Telephone number
  • Email address

If you contact us by completing one of the forms on our website, the information provided will be used solely for responding to your enquiry and administering our business relationship with you.

Information transmitted through our website forms is encrypted during transmission. However, internet-based communications cannot be guaranteed to be completely secure, and you should avoid including sensitive personal information unless specifically requested.

LAWFUL BASIS FOR PROCESSING

Polar Krush processes Personal Data under one or more of the following lawful bases:

  • Performance of a contract.
  • Compliance with a legal obligation.
  • Legitimate interests.
  • Consent where required.
  • Establishment, exercise or defence of legal claims.

Our legitimate interests include:

  • Operating and managing our business.
  • Fraud prevention and identity verification.
  • Creditworthiness and affordability assessments.
  • Maintaining information security.
  • Regulatory compliance.
  • Internal administration and record keeping.

HOW WILL POLAR KRUSH USE THE PERSONAL DATA IT COLLECTS ABOUT ME?

Polar Krush will process (collect, store and use) your information in a manner compatible with UK GDPR and the Data Protection Act 2018.

We will endeavour to keep your information accurate and up to date and will not retain it for longer than necessary.

The security of your Personal Data is paramount to us, and we have invested in several cyber security and privacy initiatives to ensure an appropriate level of protection is maintained.

We take reasonable technical and organisational measures to safeguard Personal Data against unauthorised access, loss, misuse or disclosure.

WILL YOU SHARE MY INFORMATION?

Polar Krush will never sell, rent or exchange personal information with third parties for commercial purposes.

However, we may share personal information where necessary with:

  • Credit reference agencies.
  • Regulatory authorities.
  • Professional advisers.
  • Service providers acting on our behalf.
  • Law enforcement agencies where legally required.

INTERNATIONAL DATA TRANSFERS

Some of our service providers may process personal data outside the United Kingdom.

Where personal data is transferred internationally, Polar Krush will ensure that appropriate safeguards are in place in accordance with UK GDPR, including adequacy regulations, approved contractual clauses or other lawful transfer mechanisms.

CAN I FIND OUT THE PERSONAL DATA THAT THE ORGANISATION HOLDS ABOUT ME?

Yes. You have the right to request access to the personal data we hold about you.

In addition, you have the following rights:

  • Right of access.
  • Right to rectification.
  • Right to erasure.
  • Right to restrict processing.
  • Right to object to processing.
  • Right to data portability.
  • Right to withdraw consent where consent is relied upon.
  • Rights relating to automated decision-making and profiling.

Upon request, Polar Krush can provide information including:

  • Identity and contact details of the Data Controller.
  • Contact details of the Data Protection Officer or Privacy Contact.
  • Purposes and lawful bases of processing.
  • Categories of personal data processed.
  • Categories of recipients.
  • Retention periods.
  • International transfer safeguards.
  • Information regarding your rights.
  • Sources of personal data.
  • Information relating to automated decision-making.

WHAT FORMS OF ID WILL I NEED TO PROVIDE?

Where necessary, Polar Krush may request documentation reasonably required to verify your identity before disclosing personal data.
Examples may include:

  • Passport.
  • Driving licence.
  • Utility bill.
  • Other reasonable evidence of identity.

The documentation requested will be proportionate to the nature of the request and the information sought.

CREDIT REFERENCE AND AFFORDABILITY CHECKS

To help us assess applications, prevent fraud, and meet our legal and regulatory obligations, we may obtain information about you from credit reference agencies (CRAs).

We obtain this information via Creditsafe, which uses its data partner TransUnion to supply consumer credit and identity data.

  • Creditsafe Business Solutions Limited is authorised and regulated by the Financial Conduct Authority
    FCA Firm Reference Number: 742313
  • TransUnion International UK Limited is authorised and regulated by the Financial Conduct Authority
    FCA Firm Reference Number: 737740

The information we receive may include data relating to your identity, credit commitments, payment history, and public record information. This data is used solely for legitimate business purposes, including creditworthiness assessment, identity verification, and fraud prevention, in accordance with applicable data protection laws.

Further information about how Creditsafe and TransUnion process your personal data can be found in their respective privacy notices:

Legitimate interests

Our legitimate interests include operating our business, fulfilling contractual obligations, ensuring system and data security, preventing fraud, supporting audit and compliance activities, and protecting TransUnion data. These interests are balanced against the rights and freedoms of individuals, with appropriate safeguards in place.

Data Retention Period

We keep personal data only for as long as necessary for the purposes for which it was collected and to meet legal, contractual and regulatory obligations.

Retention periods may vary depending upon the category of information processed. Personal data that is no longer required will be securely deleted, anonymised or destroyed.

Non-Automated Decision Making and Profiling

We may use automated systems and tools to support certain business processes, such as risk assessment, fraud prevention, affordability checks, identity verification, or record management.

These tools may analyse personal data using predefined criteria or rules to generate indicators, scores, or recommendations. However, we do not make decisions that have a legal or similarly significant effect on individuals based solely on automated processing. Any such decisions are subject to meaningful human review.

The use of these tools may influence the speed or level of review applied to an application or request, but individuals will not be subject to automatic rejection or adverse decisions without human involvement.

THE RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY

Polar Krush is committed to protecting your personal information. If you have concerns regarding the way we process your personal data, please contact us first using the details above.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO).

ICO Website:
https://ico.org.uk/concerns/

Contact:
dpo@polarkrush.co.uk

Last Updated: 23/06/2026