Information you give to us.

We will use this information:

• to assess your application for our products and services, for account management, arrears enforcement, for service communications, about your account; and for end of term communication to you. Our lawful bases for this processing (see below in this Privacy Policy for more details about lawful bases) are to perform our contract with you (including taking steps at your request to enter into that contract) and, in the case of assessment of your application, for our legitimate interests in ensuring our financial stability by ensuring your creditworthiness.;
• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us. Our lawful bases for this processing are to perform our contract with you (including taking steps at your request to enter into that contract) or, in the case of provision of information, for our legitimate interests in providing you with the requested information.;
• to assess your application for our services and whether you satisfy our eligibility requirements. Our lawful basis for this processing is our legitimate interests in ensuring our financial stability by ensuring your creditworthiness.;
• to verify identity in accordance with our legal obligations. Our lawful basis for this processing is to comply with our legal obligations.;
• to assess your creditworthiness including undertaking credit checks and reporting to credit referencing agencies who will retain any information we provide (including in relation to the ongoing status of your loan) and who will share this with third parties. Our lawful bases for this processing are for our legitimate interests in ensuring our financial stability by ensuring your creditworthiness and for the interests of those other third parties in ensuring their financial stability or, in the case of our initial credit check, to perform our contract with you (including taking steps at your request to enter into that contract).;
• to manage your Account. Our lawful basis for this is to perform our contract with you.;
• to deal with, assign or transfer any of our rights, interests and / or obligations under our agreement with you. Our lawful bases for this processing are to perform our contract with you or for our legitimate interests in being able to deal with our business.;
• to register you to use our App or Site, subscribe you to a service available via the App or Site and / or when you report a problem with our App or Site. Our lawful bases for this processing are to perform our contract with you (including taking steps at your request to enter into that contract) or, in the case of dealing with reported problems, for our legitimate interests in fixing our App or Site and developing our services.subject to your marketing preferences, to provide you with details of products and services that may be relevant to you (see “Direct marketing” section). Our lawful basis for this processing is that you will have consented to receive such communications (this means that consent justifies our processing of your personal data for our marketing communications).;
• to respond to any queries or other communications you submit to us. Our lawful bases for this processing are to perform our contract with you (including taking steps at your request to enter into that contract) and for our legitimate interests in responding to you and developing our services.;
• to notify you about changes to our services. Our lawful bases for this processing are to perform our contract with you and for our legitimate interests in developing our services and keeping you update to date about changes.;
• to ensure that content from our App or Site is presented in the most effective manner for you and for your computer. Our lawful basis for this processing is for our legitimate interests in providing our services, including our App and Site, as effectively as possible.; and/or
• to register or redeem for promotional campaigns. Our lawful basis for this processing is your consent or (if we enter into a contract with you specific to that campaign) to perform our contract with you or (if we don’t ask for consent and if there’s not a contract) for our legitimate interests in promoting our services by way of having our customers participate in promotional campaigns.

   

Information about your use of the App or Site

We will use this information:

• to determine which pages are the most popular, what country users come from, peak usage times and similar information;
• to administer our App or Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our App or Site to ensure that content is presented in the most effective manner for you and for your device;
• to allow you to participate in interactive features of our App or Site when you choose to do so;
• as part of our efforts to keep our App or Site safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and/or
• to make suggestions and recommendations to you about goods or services that may interest you.

Our lawful basis for the above processing is for our legitimate interests in providing our services, including our App and Site, as efficiently, effectively and securely as possible including understanding how they are used, to ensure that you can participate in interactive features, and to provide you with relevant and targeted content (including advertising and suggested recommendations). In addition, we have legitimate interests in carrying out effective marketing and customer research activities (this includes profiling about the services you’re likely to be most interested in so that we can tailor the content of direct marketing communications to this).

Information we receive from other sources

We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).

Lawful bases for processing

You’ll have seen that we’ve explained in detail our lawful bases for processing personal data for the above purposes. We’ve done that so it’s easier for you to see how your data protection law rights can be exercised (particular rights relate to different lawful bases – for instance where we rely on consent you have the right to withdraw that consent – as you’ll see from Section 2 above).

What follows below is a summary of our lawful bases. It’s also an explanation of the lawful bases which justify the other purposes for which we process your personal data, as mentioned below this section of the Privacy Policy.

Our lawful bases include:

• the performance of contracts that we have with you and processing that is necessary before you enter into the contract (we do credit reference agency checks on you for this reason);

• processing necessary for the purposes of our legitimate interests which include presenting an effective App or Site, ensuring our financial stability by assessing your creditworthiness (we process personal data for this legitimate interest whereas the check at the credit reference agency itself is lawful for the ‘contract’ reason above), providing our services efficiently and carrying out effective marketing and customer research activities (this includes profiling about the products and services you’re interested in so that we can tailor the content of direct marketing communications to this) and protecting our company against risk of fraud, money laundering and other crimes;

• processing necessary for compliance with a legal obligation, including to verify your identity and for complying with requests from a regulator or any court order; and

• We will also process your personal data based on your consent if you sign up for direct marketing communications.

When we rely on legitimate interest as a lawful basis for processing your personal data under UK GDPR, it’s important to consider a balancing test to justify this. This is about balancing on the one hand our legitimate interests in the processing (or those of third parties – for instance the interests of other third parties in ensuring their financial stability) against on the other hand your own interests, fundamental rights and freedoms and making sure that the legitimate interests we rely on are not overridden by your own interests.

Our legitimate interests described above in this Privacy Policy are not overridden by your interests, fundamental rights and freedoms, for the following reasons. Either the processing does not cause you prejudice in any way (e.g. the development of our services and efficient provision of them) or in the case of ensuring your credit worthiness, our interests in ensuring our financial stability (and those of third parties) means that we need to take steps to ensure your credit worthiness when providing services to you. If you don’t have sufficient credit worthiness it’s important for us (and others) to know that. In the case of profiling to tailor direct marketing communications to services of interest to you, your interests aren’t overridden because we won’t share that profiling information with anyone else, we only use minimal and necessary personal data to do the profiling, and the end goal of that profiling is to seek to ensure that you receive communications you’re more interested in.

If you require further information about the balancing test that we have undertaken to justify our reliance on the legitimate interest legal basis under the UK GDPR, please see “How to contact us” Section 18 for further details on how to contact us.

We may process personal data for a substantial public interest under laws that apply to us where this helps us to meet our broader social obligations such as: 

• Processing of your special categories of personal data such as about your health or if you are a vulnerable customer;
• Processing that we need to do to fulfil our legal obligations and regulatory requirements (this will include criminal convictions and offences data and it will be relevant, for instance, where we suspect fraud, money laundering or other crimes if we cannot reasonably be expected to obtain your consent to the processing); and
• When we share your personal information with other people and organisations if they need to know that you are a vulnerable customer and your relatives, social services, your carer, the person who has power of attorney over your affairs.

Sometimes we may need to ask for your explicit consent to process your sensitive personal data about your health (particularly if a substantial public interest reason doesn’t apply). In some cases, we can process your sensitive personal data on the basis that this is necessary for the establishment, exercise or defence of legal claims or before the courts.