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

that link.

Records remain on file with CRAs and FPAs for 6 years after they are closed, whether settled by you or defaulted.

More information about CRAs and how they use Personal Data is available at http://www.experian.co.uk/crain/index.html or you can contact the agencies below:

Transunion One Park Lane, Leeds, LS3 1EP Tel: 0330 024 7574 or visit www.transunion.co.uk

Equifax PLC Credit File Advice Centre, PO Box 3001, Bradford, BD1 5US Tel: 0870 010 0583 or visit www.myequifax.co.uk

Experian Consumer Help Service, PO Box 8000, Nottingham, NG80 7WF Tel: 0870 241 6212 or visit www.experian.co.uk

Our legal basis for using your Personal Data

Our use of your Personal Data as outlined above is subject to different legal bases for processing, including where necessary for:

• The purposes of the performance of our agreement with you or to take steps at your request prior to entering into an agreement with you. The provision of certain necessary information is a contractual requirement. If you do not provide such information we will be unable to provide you with a loan;
• Our legitimate interests, for example in managing and monitoring our operations, preventing fraud and for our business compliance purposes; and
• Compliance with a legal obligation, for example under consumer credit, anti-money laundering and data protection law and making reports to our regulatory authorities and to law enforcement agencies.

Where our use of your data is not necessary for one of the purposes outlined above, we may seek your consent to use it in a particular way, for example if we ask you to complete a customer survey, or request your consent to pass your information to named third parties for the purposes of marketing to you by electronic means.  Where we ask for your consent, you are free to refuse our use of the data for those purposes and you may withdraw your consent at any time by contacting us using the details set out below.

How long we will keep your Personal Data?

We will retain your Personal Data for a minimum of six years from the end of our relationship with you and until no longer needed. We may keep other information about you only to the extent necessary to comply with applicable laws and to further legitimate business needs.

Transfer of your Personal Data

All our operations are located within the UK and we do not anticipate that we will transfer your Personal Data outside the UK.  However, in the event that we do need to transfer your Personal Data outside the UK, for example if we outsource any of our loan administration services to a party located outside the UK, then before we transfer your Personal Data outside the UK we will take all steps reasonably necessary to ensure that any such transfer is made securely and that there is adequate protection in place in order to protect your Personal Data, as required by the Act, including requiring the transferee to enter into model contractual clauses where the recipient is not located in a jurisdiction that has been deemed to provide an adequate level of protection under section 17A of the Act.  Please contact us if you wish to obtain a copy of the relevant safeguards.

Security

We will take reasonable measures to protect Personal Data in our possession from loss, misuse and unauthorised access, disclosure, alteration and destruction. Personal Data is secured by us in the following ways:

• Personal Data is stored in a restricted access format;
• Personal Data will be transmitted in an encrypted format using Secure Sockets Layer (SSL) software;
• Relevant networks are secured with certified firewalls in a multi-layered manner with redundancy; and
• Network related equipment is secured with a password, and access is limited to authorised network engineers who support our equipment and systems.

We will require third parties acting on our behalf who collect or use your Personal Data under our instructions to agree to safeguard your Personal Data in accordance with this Privacy Policy and comply with data protection law.

Marketing and Opt-Out Rights

Unless you have opted out, we may contact you via email, SMS/text message or other electronic mail to inform you about other products or services provided by us that are similar to those that you have already agreed to, requested or enquired about.

You have the right at any time to ask us not to use your Personal Data for marketing purposes by notifying us using the contact details set out in the “Contact” section of this website.

Your Rights

Your Personal Data is protected under data protection law and you have a number of rights (see below) which you can seek to exercise. Please contact us in writing, by email or telephone using the details shown under ‘Contact and Complaints’ below if you wish to do so, or if you have any queries in relation to your rights. Please note these rights do not apply in all circumstances.

Right of access – subject to certain exceptions, you have the right of access to your Personal Data that we hold.

Right to rectify your Personal Data – If you discover that the Personal Data we hold about you is inaccurate or incomplete, you have the right to have this information rectified (i.e. corrected).

Right to be forgotten – You may ask us to delete information we hold about you in certain circumstances. This right is not absolute and it may not be possible for us to delete the information we hold about you, for example, if we have an ongoing contractual relationship or are required to retain information to comply with our legal obligations.

Right to restriction of processing – In some cases you may have the right to have the processing of your Personal Data restricted. For example, where you contest the accuracy of your Personal Data, its use may be restricted until the accuracy is verified.

Right to object to processing – You may object to the processing of your Personal Data (including profiling) when it is based upon our legitimate interests. You may also object to the processing of your Personal Data for the purposes of direct marketing and for the purposes of statistical analysis.

Right to data portability – You have the right to receive, move, copy or transfer your Personal Data to another controller when we are processing your Personal Data based on consent or on a contract and the processing is carried out by automated means.

Changes to This Privacy Policy

This Policy may be amended from time to time and we will give you notice of material changes by sending notification to you via the post.

Contact & Complaints

If you have any questions about how we treat your personal data and protect your privacy, if you have any comments or wish to seek to exercise any of your rights as outlined above or to complain, please contact the Data Protection Officer:

• By post to Family Finance Ltd, 93 Commercial Street, Tredegar, Gwent NP22 3DN
• By email to enquiries@familyfinance.ltd.uk
• By telephoning us on 01495 726565

You may also lodge a complaint with the Information Commissioner’s Office, Water Lane, Wilmslow, SK9 5AF telephone 0303 123 1113. www.ico.org.uk.

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