Privacy Policy
Last Updated: October 6, 2026
At SURA Limited, trading as Nucap (“Nucap”), protecting your corporate and personal data is a core operational priority. This Privacy Policy outlines how we collect, process, protect, and share data in strict compliance with the General Data Protection Regulation (GDPR) and the Irish Data Protection Acts 1988–2018.
1. Data Controller
The Data Controller responsible for your personal data is:
SURA Limited, trading as Nucap
Email Contact: paul@nucap.ie
2. Data We Collect
Because we operate a commercial credit-matching platform, we collect both personal and corporate data during your application:
Identity Data: Full name of the applicant director.
Contact Data: Corporate email address, mobile phone number, and business trading address.
Corporate Data: Official Company Name, CRO Company Registration Number, legal entity structure, trading age, and payment collection methodology.
Financial Metrics: Estimated annual turnover, monthly card/online processing volumes, and loan requirement parameters.
Enriched Data: Publicly available corporate data retrieved programmatically from the Companies Registration Office (CRO), including active registration status, director registries, and mortgage/charge files.
Note on Bank Statements: Nucap does not collect, parse, or store open banking credentials or raw bank statement PDFs at the initial intake stage. These are requested and processed directly by your matched lender during formal underwriting.
3. How and Why We Process Your Data (Legal Basis)
We process your personal and corporate data under the following legal bases under GDPR:
Processing Activity
Data Categories
Legal Basis under GDPR
Verifying Company Registry
CRO Number, Company Name
Legitimate Interest: Verifying that the business is a legally active Irish LTD before routing [1, 2].
Running Matching Engine
Turnover, Facility Need, Payment Method
Performance of a Contract: Fulfilling our service to match you with compatible lenders.
Transmitting to Lenders
Director Name, Phone, Email, Deal Memo
Explicit Consent: You explicitly instruct us to introduce your file to matched underwriters.
CRM Pipeline Tracking
All submitted fields
Legitimate Interest: Managing our broker commissions, audit trails, and partner attribution.
4. How Data is Shared with Our Partners
To fulfill our service, we securely share your pre-screened commercial profile with our approved panel of non-bank lenders (including, but not limited to, Capitalflow, Linked Finance, Bibby Financial Services, Close Brothers, and 365 Business Finance).
THE SAFETY PROTOCOL:
We never sell your data to consumer marketing databases, third-party lead brokers, or unsolicited call centers.
We only transmit your data to the specific, matched lenders identified by our decision-tree algorithm.
Matched lenders are bound by strict corporate confidentiality agreements and are permitted to use your data solely to assess credit viability and issue indicative term sheets.
5. Data Retention
We retain your pipeline data in our secure, encrypted database (hosted via Google Sheets and Airtable) for a period of 5 years from the date of submission. This retention window is strictly required to:
Validate broker commission claims and track drawdown attributions with our panel lenders.
Comply with statutory business audit and tax records retention requirements in Ireland.
6. Your Rights Under GDPR
As an Irish/EU resident, you possess the following rights regarding the personal data we hold:
Right of Access: Request a copy of the personal data we hold about you.
Right to Rectification: Request corrections to any inaccurate or incomplete data.
Right to Erasure (Right to be Forgotten): Request that we delete your personal data (subject to our legal requirements to retain files for commission audit trails).
Right to Withdraw Consent: You can withdraw your consent to lender introductions at any point prior to data transmission by emailing paul@nucap.ie.
7. Contact and Complaints
If you have any questions regarding this Privacy Policy or wish to exercise your data rights, please contact us at paul@nucap.ie.
If you believe we have processed your data unlawfully, you have the right to lodge a complaint with the Data Protection Commission (DPC) of Ireland (info@dataprotection.ie).