This Policy, together with our Website Terms and Conditions, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data.
1. Information we may collect from you
1.1. We may collect and process the following data about you:
1.1.1. information that you may provide by filling in online forms and registration forms (including registering for products, services or newsletters) on the Sites . This includes information provided at the time when you complete an online Application Form on our Sites, or request further services. We may also ask you for information in the event you report a problem with our Sites;
1.1.2. correspondence, or a record of it if you should contact us, together with your contact details and our responses;
1.1.3. surveys that we use for research purposes, which we have asked you to complete, although you do not have to respond to them;
1.1.4. details of your visits to our Sites (including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise) and the resources that you access; and
1.1.5. information from third parties in respect of you which may include your employer, a referee or a person residing or working from another country.
2. How we use your information
2.1. We use information held about you in the following ways:
2.1.1. to process and submit your Application Form to credit brokers, lenders and/or third party marketing partners (the "Advertising Partners");
2.1.2. to provide you with the best possible service;
2.1.3. to ensure that content from our Sites is presented in the most effective manner for you and for your computer; and
2.1.4. to notify you about changes to our products and services.
2.2. In addition to the above, we may disclose your personal information to third parties:
2.2.1. to prepare or send any communications to you, or to assist us in connection with any of our administrative or business functions, or in the provision of any of our services to you;
2.2.2. if the Company or substantially all of its assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
2.2.3. if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions of Use and other agreements; or to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
2.3. It is sometimes necessary the Company to transfer information held about you to lenders and brokers based outside of the European Economic Area. The Eighth Data Protection Principle of the Act restricts the transfer of personal data to a country outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects. By submitting your Application Form you consent to this transfer. You may withdraw your consent at a later date by writing to us at [email protected] or Smart Loans UK, 8a Dunraven Place, Bridgend, CF31 1JD.
2.4. You agree that we and our panel of lenders and brokers may use your information for marketing purposes to provide you with details about goods and services such as but not limited to finance, claims, automative, utilities, telecoms, which may be of interest to you, and we may contact you about these by post, SMS and E-mail.
2.5. When you submit and Application Form you will be required to consent to the passing of your information to third parties who may use it to assess your creditworthiness and contact you directly in respect of your application for credit or for marketing purposes. If you do not wish to receive communications from our Advertising Partners offering goods or services which may be of interest to you, then do not submit an Application Form via the Sites.
2.6. If you wish to opt-out of receipt of marketing communications from us at any time you may do so by sending an email to us at [email protected] or by contacting us at Smart Loans UK, 8a Dunraven Place, Bridgend, CF31 1JD.
2.7. If you opt-out of our use of your data for marketing purposes, we will honour such choice once we have had a reasonable opportunity to process your request. We reserve the right to take reasonable steps to authenticate your identity with respect to any such request or other enquiry.
2.8. From time to time our Sites request information from user via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose this information. Information requested may include contact information (such as name or address) and demographic information (such as age and gender). Contact information will be used to notify the winners and award prizes. Survey information will be used for the purpose of monitoring or improving the use and satisfaction of the Sites.
2.9. Any information or statistics relating to our business that we disclose to others shall not identify you personally. We may, for example, perform statistical analysis of the behaviour of the users of our Sites in order to measure interest in the various areas of our Sites and to inform advertisers as to how many consumers have seen or "clicked" their advertising banners. This information, and any other general information about our users that we share with advertisers and other partners, will not disclose personal information about you.
3. Secure storage of your personal data
3.1. All information you provide to us is, as far as reasonably practicable, stored on our secure servers. Any financial information, such as credit/debit card numbers will be encrypted using SSL and 3-D Secure technology. We ask you not to permit anyone to use your name.
3.2. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Sites; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
3.3. We will retain your information securely stored for a reasonable period or for as long as the law requires.
4. IP addresses and cookies
4.1. We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.
4.2. A "cookie" is a small electronic file that collects information when someone visits a website. A cookie can identify the pages that are being viewed, and this can assist us to select the pages that the viewer sees. Some cookies only exist whilst viewers are online, but "persistent" cookies - which are not session-based - remain on the viewer's computer, so that he or she can be recognised as a previous visitor when he or she next visits our website. This allows us to collect information about a viewer's browsing habits whilst on our Sites, and this can be useful in assisting us to monitor and improve our services.
4.3. The Company may release browsing data and information gathered using cookies in the aggregate, such as publishing a report on trends in the usage of the Sites. The report will only contain statistical data and will not identify any individual.
4.4. We do not store sensitive information such as account numbers or passwords in "persistent" cookies, and cookies in themselves, do not contain enough information to identify you. You will only acquire a personal identity in relation to your browsing habits after you have formally provided us with your personal data for the purposes outlined at 2 above.
4.5. In addition to using cookies, we might also use web tools to collect information about your browsing activities whilst on our Sites. In this respect the information that is provided is similar to the information supplied by cookies, and we use it for the same purposes.
4.6. Any information that we acquire about you using cookies or web tools is subject to the same restrictions and conditions as any other information we collect about you.
5. Your rights
5.1. Our Sites may, from time to time, contain links to and from the websites of our advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
5.2. We will store and process your information on our computers and in any other way we consider appropriate. By "your information" we mean personal and financial information we (a) obtain from you or from third parties, such as credit reference agencies (who may search the Electoral Register), fraud prevention agencies or other organisations when you apply for a loan.
5.3. We will use your information to provide our services, for research, assessment and analysis (including credit and/or behaviour scoring, market and product analysis) and to develop and improve our services to you and other customers and protect our interests.
5.4. You have the following rights regarding the processing of your personal data, given to you through legislation. You can contact us about any of them by emailing us at: [email protected] or by writing to us at: Smart Loans UK, 8a Dunraven Place, Bridgend CF31 1JD. Any access request will be free of charge.
5.4.2. The right of access. You have the right to obtain confirmation that your data is being processed and to have access to that personal data.
5.4.3. The right to rectification. You have the right to have your personal data rectified if it is incorrect or incomplete.
5.4.4. The right to erasure. You have a right to be forgotten, or to have your personal data erased and to prevent processing. The right is not absolute and in certain circumstances this may not be possible.
5.4.5. The right to restrict processing. You have the right to block or suppress the processing of your personal data. This does not stop the storing of your personal data, as it may be required to restrict processing in the future.
5.4.6. The right to data portability. You have the right to obtain and reuse your personal data for your own purposes across different services in a safe and secure way, without hindrance to usability.
5.4.7. The right to object. You have the right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); direct marketing (including profiling); and processing for purposes of scientific/historical research and statistics.
5.4.8. Rights in relation to automated decision making and profiling. You have a right to object to automated decision making, to express your point of view, ask for human intervention, and to be provided with an explanation of the decision with your option to challenge it. The right is not absolute and is not applicable for the entering into a consumer credit agreement.
5.4.9. The right to withdraw consent. If you have given us explicit consent to process your personal data you have a right to withdraw that consent at any time, including but not limited to the removal of consent to be contacted by third party marketers.
5.4.10. The right to lodge a complaint with a supervisory authority. You have the right to lodge a complaint with us directly and / or with a supervisory authority. In the UK the relevant authority is the Information Commissioner?s Office (ICO). You can find their contact details at ico.org.uk/global/contact-us
5.5. Calls between us may be recorded and/or monitored.
5.6. If you were introduced to us by a third party, we will give them your contact details and sufficient information about you for their accounting and administration purposes.
5.7. We may give information about you and how you manage your account to the following:
5.7.1. people who provide a service to us or are acting as our agents on the understanding that they will keep the information confidential. If they are located in another country we will make sure that they agree to apply the same levels of protection as we are required to apply to information held in the UK and to use your information only for the purpose of providing the service to us;
5.7.2. anyone to whom we transfer or may transfer our rights and duties under this agreement;
5.7.3. we may also give out information about you if we have a duty to do so or if the law allows us to do so.
5.8. Otherwise we will keep information about you confidential.
6. Credit Reference and Fraud Prevention Agencies
6.1. When you submit an Application Form you confirm that all the information you have given is true and complete. When you submit an Application Form you authorise our Advertising Partners to check the following records about you and others:
6.1.1. our own;
6.1.2. those at credit reference agencies (CRAs); and
6.1.3. those at fraud prevention agencies (FPAs).
6.2. Our Advertising Partners will make checks such as are deemed necessary to assess your application for credit.
6.3. If you tell us that you have a spouse or financial associate, we will link your records together so you must be sure that you have their agreement to disclose information about them. CRAs also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.
6.4. If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies.
6.5. Law enforcement agencies may access and use this information.
6.6. We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:
6.6.1. checking details on applications for credit and credit related or other facilities;
6.6.2. managing credit and credit related accounts or facilities;
6.6.3. recovering debt;
6.6.4. checking details on proposals and claims for all types of insurance; or
6.6.5. checking details of job applicants and employees.
6.7. We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.
6.8. Your data may also be used for other purposes for which you give your specific permission or, in very limited circumstances, when required by law or where permitted under the terms of the Data Protection Act 1998.
6.9. Our lenders with whom we share your information may use it for their legitimate business interests to match applications, carry out fraud checks, carry out research such as analysis of market trends and customer demographics and to customise and develop the product/service which they offer to you or other individuals in the future. Most lenders might use this for up to 12 months.
7.2. If the Policy changes in the future, we will not use the personal information you have submitted to us under the Policy in a manner that is materially inconsistent with this Policy, without your prior consent.
8. William Ellis Sinclair Panel of Lenders, Brokers and Data Controllers
- 1plus1 Loans Limited
- Active Securities Limited
- Advancis Limited
- Amigo Loans Ltd
- Bamboo Limited
- Butler Westbury Limited
- Cash on Go Ltd
- CashEuroNet UK LLC
- Curo Transatlantic Limited
- DJS (UK) Limited
- Elevate Credit International Limited
- Evergreen Finance London Ltd (trading as MoneyBoat.co.uk)
- Everyday Lending Limited
- Ferratum UK Ltd
- Fizzyy Ltd
- Forefront Solution Ltd
- Gain Credit LLC
- George Banco.com Limited
- Gracombex Ltd
- Harvey & Thompson Limited
- Hymarc Limited
- Ineffable Limited
- Indigo Michael Limited
- Lead Byte Limited
- Lend A Hand Finance Ltd
- Loan Machine Limited
- Loan Marketing Limited
- Loans 2 Go Limited
- Match the Cash Limited
- Mindflow Marketing Limited
- MMP Financial Limited
- Mobile Money Ltd
- Morses Club PLC
- My Finance Club Limited
- MYJAR Limited
- Nextcredit Limited
- Novaloans Ltd
- PDL Finance Limited
- Ping Technologies Ltd
- Provident Personal Credit Limited
- Quint Group Limited
- RS Datatech
- Sandhurst Associates Limited
- Savant International Limited
- ScoresMatter Ltd
- Serpable Limited
- Silver City Tech Limited
- Stagemount Limited
- T Dot UK Limited
- TFLI Limited
- TFS Loans Limited
- The 1st Stop Group Limited
- The Money Platform
- The Quick Loan Shop Ltd
- TM Advances Limited
- Total Home Loans Direct Limited
- Trusted Cash Limited
- UK Credit Limited
- Uncle Buck Finance LLP
- Valour Finance Limited
- Western Circle Limited
- William Ellis Sinclair
- Yes Solutions Ltd
- Yes Catalogue Ltd
- Credit Reporting Agency Limited
- Direct Link Technologies Ltd
- Durham Technology Limited
- Equifax Limited
- Media Blanket Ltd