How we collect your Personal Data

We collect Personal Data directly from you via communications between us when you use or apply to use our

services, including when you apply to us for a loan via a credit broker and they transfer your personal data to us in accordance with your agreement with them. This includes:

• your name, date of birth, home address(es), telephone number(s), email address(es), financial information (such as bank account and salary details) and employment information;
• information about your transactions with us, such as payment history and loan balances, and information provided when interacting with our customer service representatives;
• other personal Data you voluntarily provide, which may include special category personal data, for example data which you provide about your health where this relates to your ability to meet your obligations under the agreement.

We also collect your Personal Data from third parties:

• from searches of Credit Reference Agencies (CRAs) of their records relating to you and other people with whom you are linked financially;
• from public records (e.g. the electoral roll);
• from other third parties with your consent (for example a credit broker).

How we use your Personal Data

We use your Personal Data which we collect as set out above to:

• verify your identity and employment status;
• assess your credit history and make credit decisions about you;
• communicate with you by telephone, email, SMS, or post;
• meet our legal, regulatory and contractual obligations arising from any loan agreement you enter into with us;
• manage your account, make collections, trace you and recover debts owed by you;
• prevent fraud and money laundering;
• report positive, delinquent and default data to CRAs
• provide you with information about other products and services we offer that are similar to those that you have already entered into, requested or enquired about;
• provide and improve customer service and support;
• enhance operational capabilities and for internal operations;
• verify or enforce compliance with this Privacy Policy and applicable laws.

Sharing your Personal Data

We may share your Personal Data with certain third parties where we have a legal basis to do so. Common third parties who may share your Personal Data include;

• third parties to which we transfer, charge or assign your agreement or which provide services for us;
• to the purchaser or seller of or investor in any business or asset (including the sale or transfer of a loan) which we are (or are contemplating) selling or purchasing and their advisors or service providers;
• in connection with any legal proceedings or prospective legal proceedings or for establishing, exercising or defending legal rights;
• law enforcement agencies or regulatory bodies where we are required to do so by law;
  and
• CRAs and Fraud Prevention Agencies (FPAs)

Credit Reference Agencies

In order to process your application, we will perform credit and identity checks on you with one or more CRAs. To do this, we will supply your Personal Data to CRAs and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.
We will use this information to:

• Assess your creditworthiness and whether you can afford to take the product;
• Verify the accuracy of the data you have provided to us;
• Prevent criminal activity, fraud and money laundering;
• Manage your account(s);
• Trace and recover debts; and
• Ensure any offers provided to you are appropriate to your circumstances.

We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs.

When CRAs receive a search from us they will place a search “footprint” on your credit file which can be seen by other lenders whether or not the application proceeds.

If you are making a joint application, or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. CRAs will 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

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Effective Date: 20-Jun-2023
Last Updated: 20-Jun-2023

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