Data Sharing Agreement

1. Purpose

The Loan Intel platform operates on a shared intelligence model. Members contribute data about their loan portfolios. In return, they receive anonymised market intelligence, cross-lender alerts, and benchmarking data derived from the contributions of all members.

This DSA sets out exactly what data you share, how it is processed, what is visible to other members, and what protections are in place.

2. Data You Contribute

When you upload or enter data into the platform, you may contribute the following categories of information:

2.1 Loan Book Data

• SPV/borrower company name and Companies House number
• Facility type (bridging, development finance, or term loan)
• Facility amount, interest rate, and loan term
• LTV, LTGDV, and loan-to-cost ratios
• Loan start and expiry dates
• Interest structure (paid current, rolled up, or hybrid)
• Valuation data (current, 90-day, GDV)
• Exit strategy type and status
• Construction facility details (development finance only)
• Retention amounts (bridging refurbishment only)

2.2 Payment Data

• Monthly payment status (on time, late, missed, arrears, default)
• Days late and arrears months
• Payment amounts
• Current LTV at time of payment

2.3 Declined Applications

• Company number and name of the declined borrower
• Decline reason
• Date of decline

2.4 Insurance Data

• Insurer names and policy references
• Policy expiry dates
• Broker contact details
• CAR insurance and latent defect warranty details (development finance)

2.5 Tenant Data

• Tenant company name and Companies House number
• Lease terms, rent amounts, and break dates

2.6 What You Do Not Share

The following data is never contributed or shared with the platform:

• Personal data of borrowers (names, addresses, dates of birth of individuals)
• Bank account details or sort codes
• Solicitor or valuer panel information
• Internal credit committee notes or decisioning rationale
• Your own financial position or balance sheet data

3. How Your Data Is Protected

3.1 Ring-Fencing

Your contributed data is ring-fenced within your account. No other member can see your loan book, your facility amounts, your interest rates, your LTV positions, or your insurance details. Your portfolio data is yours alone.

3.2 Lender Identity Protection

Your identity as a lender is never disclosed to other members. When cross-lender alerts are generated, they state that “a lender” has reported an event. They do not identify which lender, the facility amount, the interest rate, or any other detail that could identify you.

3.3 Technical Safeguards

• All data is encrypted at rest and in transit (TLS 1.2+)
• Data is stored on UK-based servers only
• Access is controlled by authenticated sessions with two-factor verification
• API access requires per-account API keys with rate limiting
• Database queries are scoped to your lender ID at the application layer
• Audit logging tracks all data access and modifications

4. What Other Members Can See

This section sets out exactly what information is visible to other platform members as a result of your data contributions. If it is not listed here, it is not shared.

4.1 Cross-Lender Payment Alerts

When you report a late, missed, arrears, or default payment, other members who have the same borrower (or a borrower sharing the same directors/PSCs) in their own loan book will receive an alert containing:

• The company name and number of the affected SPV
• The type of event (late, missed, arrears, default)
• The month the event relates to

The alert does not contain:

• Your identity as the reporting lender
• Your facility amount, interest rate, or LTV
• The number of days late or the arrears amount
• Any PSC or director names (the connection is made internally but not disclosed)

4.2 Declined Application Alerts

When you record a declined application, other members monitoring the same borrower network will receive an anonymised notification. The notification states that a decline has been recorded. It does not identify you or your decline reason.

4.3 Market Benchmarking Data

Your contributed data may be included in aggregated, anonymised market benchmarks. These benchmarks show market-level statistics such as:

• Average LTV by facility type across all members
• Average interest rates by facility type
• Average facility size by facility type
• Distribution of facility types across the market

Benchmarks require a minimum number of contributing members before they are displayed. Individual data points are never identifiable within benchmarks.

4.4 Monitoring Counts

When viewing a borrower profile, members can see how many other lenders are monitoring the same company. They cannot see which lenders or any details about those lenders’ positions.

4.5 What Is Never Shared

5. How Your Data Is Used

Your contributed data is used for the following purposes:

1. Your own portfolio management. Tracking your loan book, monitoring payments, managing insurance, and generating reports for your internal use.
2. Cross-lender network alerts. Generating anonymised alerts when a borrower in your portfolio, or a borrower sharing directors with one in your portfolio, is reported as having payment issues by another member.
3. Market benchmarking. Contributing to aggregated, anonymised market statistics that help all members understand market conditions.
4. Platform intelligence. Generating health scores, risk indicators, and monitoring signals for borrower companies in the platform’s database.
5. Improving the platform. Analysing usage patterns and data quality to improve platform features and accuracy.

Your data is never sold to third parties. Your data is never used for marketing purposes by TPCF. Your data is never shared with other members except as described in Section 4 above.

6. Data Quality and Accuracy

You are responsible for ensuring that the data you contribute is accurate and up to date. Inaccurate payment data can trigger false alerts for other members and undermine confidence in the platform.

If you discover that data you have submitted is incorrect, you should correct it promptly through the platform interface. If you record a payment as “late” and subsequently receive payment, update the record to reflect the correct status.

7. Data Import Methods

The platform supports the following methods for contributing loan book data:

• Manual entry. Add loans individually through the platform interface.
• CSV/Excel upload. Upload your loan book in bulk using our template. Available at any time from the Loan Management page.
• API integration. Push data from your existing systems via the platform REST API. API documentation is available at /support/api-docs.

If you already use a loan management system (such as Airtable, Lenvi, or a bespoke system), we can work with you to set up an automated sync so you do not need to maintain data in two places. Contact support@loan-intel.com to discuss integration options.

8. Withdrawing Your Data

8.1 Deleting Individual Records

You can delete individual loans, payment records, and declined applications from your account at any time through the platform interface. Deleted records are removed from your portfolio and will no longer generate alerts or contribute to benchmarks.

8.2 Full Data Withdrawal

You may request a full withdrawal of all your contributed data by contacting support@loan-intel.com. Upon receiving your request, we will:

1. Remove all your loan book entries, payment records, and declined applications within 30 days
2. Remove your data from future benchmark calculations
3. Provide you with a complete export of your data in CSV format upon request

Data that has already been incorporated into historical aggregated benchmarks cannot be individually extracted, as it has been anonymised and combined with data from other members. Alerts that were previously sent based on your contributed data cannot be recalled.

8.3 Account Closure

If you close your account, the data withdrawal process in Section 8.2 applies automatically. Your personal data (name, email, login history) will be retained for a maximum of 90 days after closure for audit purposes, then permanently deleted.

9. Reciprocity Principle

The platform operates on a principle of reciprocity. Members who contribute data receive the full benefit of the platform’s intelligence capabilities. Members who do not contribute data will have limited access to cross-lender features.

Specifically:

• Cross-lender payment alerts are only generated for companies in your contributed loan book
• Market benchmarking comparisons require you to have contributed your own data for comparison
• Monitoring counts are only visible for companies you have added to your portfolio

This ensures that the intelligence value of the platform scales with participation and that no member benefits disproportionately without contributing.

10. Legal Basis for Data Sharing

The data you contribute relates to corporate entities (SPVs, borrower companies) registered at Companies House. It does not constitute personal data under UK GDPR, as SPVs are legal entities, not natural persons.

Where contributed data incidentally includes references to individuals (such as director names sourced from Companies House public records), this data is processed under TPCF’s legitimate interest in providing market intelligence services to the specialist lending sector. Director and PSC data is sourced from the Companies House public register and is used solely for corporate network analysis. It is never disclosed to other members.

Your personal data (name, email, contact details provided during registration) is processed under the contractual basis set out in our Data Processing Agreement.

11. Changes to This Agreement

TPCF may update this DSA from time to time to reflect changes in the platform’s data sharing capabilities or regulatory requirements. Material changes will be communicated to you via email at least 14 days before they take effect. Your continued use of the platform after the effective date constitutes acceptance of the updated DSA.

12. Contact

For questions about this Data Sharing Agreement or how your data is used: