Advertisement Policy

1

Who are we?

Welcome to Western Circle Ltd trading as Cashfloat.co.uk

Our registered office address:
2a Highfield Avenue, London NW11 9ET

We are a company registered in:
England and Wales under company number 7581337.

We are registered:
Information Commissioner’s Office Register: registration number Z3305234,
We act as the data controller when processing your data.

Western Circle Limited is committed to 100% fair marketing. We go above and beyond our regulatory obligation, saving no efforts in creating easy to read, straight forward and helpful advertisement.

In all our ads and digital promotions we ensure that our client understands exactly what he gets. We are not aiming to mislead our client in any way. However, if you find any of our advertisement materials to be misleading or unclear please do not hesitate to contact us and we will fix it immediately.

2

Developing Marketing Strategies

Western Circle Limited establishes its advertising and marketing strategies/concepts in advance of any release or publication. Every single ad that we publish is controlled directly by us. We always make sure to check any material prior to its publication to make sure it is in accordance with the legislative and regulatory requirements.

You may ask, why is Cashfloat not advertising on TV or in newspapers?

Let’s be honest. All those funny cartoon characters on TV trying to convince people to take a loan are not helpful, are they? Our focus is on quality, and effective communication. We do not use childish characters to paint the business as a nicer picture than it really is.

Actually, we love the way we look. We invest a lot of effort to ensure that our clients understand exactly who we are, and what product they are getting. We simply do not need additional artificial kickers. Every month, more and more people come to our website, experiencing a completely new level of direct lending.

3

How to Spot Us

All our adverts will contain:

Western Circle Limited’s full company name.
An address or a contact point from which an address is available.
Clear, fair, and transparent content.
Plain and intelligible language, (or in the case of oral promotions, clearly audible)
Accuracy of all statements of fact at the time of publication.
Legal, decent, honest and truthful content.
A clear promotional purpose, which is not in any way disguised or misrepresented.
Language that does not exploit the credulity, lack of knowledge or inexperience of consumers.
Clear features of any product: We will clearly demonstrate the possible disadvantages as well as the advantages associated with any feature.
Clarification of any important limitations or qualifications, without which a misleading impression of a product or service that might be given.
Descriptions, claims or other material which will not directly or by implication, mislead about the product or service advertised, or about its suitability for the purpose recommended.
An adequate description of the product being promoted.

4

Design/Content

The design, content or format of Cashfloat’s advertising will not in any way disguise, obscure or diminish the significance of any statement, warning or other matter which the promotion is required to contain. In addition to this:

Our email/post promotions are designed and presented in a way that it is clear that they are marketing communications without the need to open them.
Will not contain anything that is likely to cause serious or widespread offence.
Particular care is taken to avoid causing offence on the grounds of race, religion, sex, sexual orientation or disability.
We do not use marketing communication that may cause fear or distress without good reason, and do not use shocking claims or images merely to attract attention.
Offensive and profane language is forcefully avoided
Use is made of the positioning of text; background and text colour and type size to ensure that prescribed information is presented prominently.

5

Statements and Opinions

It is important for any company, as well as Western Circle trading as Cashfloat, to present quotes as truthfully and as accurately as possible. We therefore make sure that:

Any statement of fact, promise or prediction is clear, fair and not misleading and any relevant assumptions are clearly and prominently disclosed at the time.
Any statement of opinion is honestly held and, unless consent is impracticable, given with the written consent of the person concerned.
Where only part of an opinion is quoted, it will nevertheless be a fair representative.
Any connection between the holder of the opinion and the firm will be made clear.
We do not include any reference to approval by the FCA, or any governmental body, unless such approval has been obtained in writing from the FCA, or that body.
Obvious untruths or exaggerations that are unlikely to mislead and incidental minor errors and unorthodox spellings are all allowed, provided they do not affect the accuracy or perception of the marketing communication in any material way.
Testimonials relate to the product being advertised.
Fictitious testimonials are not presented as though they are genuine.
Absolute claims e.g. ‘best on the market’, ‘lowest prices guaranteed’ are avoided unless they are backed up by clear evidence and are based on a formula against which Western Circle Limited can completely deliver.

6

Competitors

As a highly competitive market, Cashfloat look to only represent themselves as exactly where they are in the market. We therefore try hard to:

Create absolute clarity in the marketplace between Western Circle Limited itself and a competitor or between Western Circle Limited’s trademarks, trade names, other distinguishing marks, products and those of a competitor.
Avoid discrediting or denigrating the trademarks, trade names, products, services, activities or circumstances of a competitor
Ensure that we do not present a product or service as an imitation or replica of another product or service bearing a protected trademark or trade name.
Allow comparative claims in the interests of vigorous competition and public information.
Respect the principles of fair competition, and the comparisons used are not likely to mislead consumers about either product.
Base points of comparison fairly on selected facts which can be substantiated.
Choose comparisons that do not give the advertiser an artificial advantage over our competitor.

7

Comparisons

Cashfloat tries to make its comparisons as accurately as possible. For example, we:

Include all factors which are relevant to the comparison or contrast
Indicate in a clear and unequivocal way in a comparison referring to a special offer, the date on which the offer ends or, where appropriate, that the special offer is subject to the availability of the contracts and services and, where the special offer has not yet begun, the date of the start of the period during which the special price or other specific conditions shall apply.
Accurately state the actual or comparative prices. In addition, the manner in which a price is to be calculated is accurate and does not mislead by omission, undue emphasis or distortion.

8

Required Terms

As a responsible lender, we make every effort not to mislead companies by using inaccurate or confusing terms and jargon. Here at Cashfloat, we only advertise:

A promotion which, when describing any cash back offered to the customer, also clearly refers to any relevant conditions, such as a requirement to pay back some or all of the cash back on early repayment.
A promotion which when describing any possible monetary saving, also clearly states how this could be achieved.
A promotion which when including references to non-standard services or facilities, also clearly states that an additional fee may be payable for these.

Promotions that do not contain any of the following words or expressions, unless the relevant condition applies:

“No deposit” or any similar expression, except where no advance payments are required to be made.
The expression “gift”, “present” or any similar expressions, unless there are no conditions which would require the customer to return the money or items that are the subject of the claim.
The expression ‘interest free’ or any similar expression (such as 0% Finance or Interest Free Option) except where the total amount payable by the customer does not exceed the credit.

9

Additional points

If a promotion includes information on the performance of Western Circle Limited, on conditions in the market, interest rates, APR’s or other price information this information will be relevant and recent.
If designed for a targeted collection of customers who are reasonably believed to have particular knowledge of the product being promoted, this fact will be made clear
If it features a product which is conditional upon the customer obtaining one or further products from Western Circle Limited (or its agents or associates) will state the compulsory nature of these purchases.
All price claims such as “up to” and “from” do not exaggerate the availability of benefits likely to be obtained by consumers.

This policy was written to help our website visitors understand our business and code of practice. We simplify the language to make it easier for everybody to know who we are, what we provide and how we do it. If you have any comment or require additional information please contact us. We have developed some of the industry leading procedures to ensure we serve our clients with dignity, integrity and truthfulness.