1plus1 Loans Limited ("we", “us” or “our”) are committed to protecting and respecting your privacy.
This policy (together with our terms and conditions, which you can find here; Terms & Conditions and any other documents referred to on it) sets out the basis on which any personal data which we collect from you, or that you provide to us, either through 1Plus1loans.co.uk (“our site”) or otherwise, will be processed by us. Please read this policy carefully to ensure that you understand our views and practices regarding your personal data, and how we will treat it. By visiting www.1plus1loans.co.uk or providing your personal data to us, you are accepting and consenting to the practices described in this policy.
What is our commitment to you?
We are committed to protecting and respecting your privacy and to ensuring that your personal details are kept private and confidential at all times, even when your contract with us as a customer or guarantor has ended and you are no longer bound to us. We will only make use of or share your personal data in accordance with this policy, or otherwise only if we are required to do so by law.
Information about us
For the purposes of the European General Data Protection Regulation (‘GDPR’) and UK Data Protection Act 2018 (‘DPA’) the data controller responsible for your personal data is 1plus1 Loans Limited, The Old Tannery, Eastgate, Accrington, Lancashire BB5 6PW. Under the GDPR and DPA as data controller to use your personal information, we must have a lawful basis for doing so, including the sharing of your information outside 1plus1 Loans Limited, for example with Credit Reference Agencies. We process your personal data under one or more of the following lawful bases under the GDPR and DPA:
- To enter into a contract with you, or
- When it is our legal duty, or
- Where there is a legitimate interest, or
- When you consent to it
Below is a list of the ways in which we will use your personal information, the lawful basis we rely on to process it and where we process based on legitimate interests, what these are.
Our legal basis for processing personal data
We need to collect your personal information in order to enter into a finance contract with you.
Under GDPR and DPA, our lawful basis for processing your personal information is as follows
- To provide you with our products and services
- To allow us to process your application, we will use your personal information to assess your suitability for finance
- Lawful Basis: Fulfilling a Contract, Legal Duty, Legitimate Interests - promoting responsible lending and helping to prevent over indebtedness; to prevent, detect, investigate and report financial crime
- To manage our agreement and relationship with you
- We will process your information to ensure that you are able to fulfil your obligations under your credit agreement and to communicate with you to provide and manage your needs.
- Lawful Basis: Fulfilling a Contract, Legal Duty, Legitimate Interests - to manage your agreement with us and ensure repayments are made and received
- To meet our Legal Obligations
- We may process your information for the prevention, detection and investigation of fraud and money laundering and to comply with laws and regulations that we have to adhere as a regulated credit provider; and to meet our obligations if we are required to disclose information by reason of any law, regulation or court order
- Lawful Basis: Legal Duty
- To send you details of our products and services
- To provide you with information on other products and services we can offer you
Lawful Basis: Consent, Legitimate Interests - to send information on similar products where you have not previously objected where these products and services may be of genuine interest to you, for example when your current loan repaid or where there are possible alternatives available to you during the term of your loan
What personal data do we collect about you?
The categories of personal data we collect from you are:
- Personal Identifiers - Information which can identify you, such as your name and date of birth.
- Contact Details - Information on where you live and how we may contact you to discuss your agreement.
- Financial Details - Your financial position, history and bank account information
- Employment - Your current employment status and employment history
- Documentary Data - Documents provided by you, for example Passport, Driving Licence, Payslips, Bank Statements
- Public Records and Open Data - Information about you on public records such as the Electoral Register and information which is openly available on the internet
- Location Data - Information we receive from your device (mobile phone, computer etc.) when you visit our website or log on to your online account
- Special Category Data - Certain personal information you provide to us is more sensitive and needs more protection. We will only collect and process this type of data with your consent. Examples of this type of data may include information you provide in relation to a vulnerability which we need to be aware of to provide support and correctly manage our relationship with you
We may also collect and process the following data about you when you visit our website:
- Information which you give to us. You may provide us with information about you by filling in forms on our site (including when you apply for a loan or guarantee or make an enquiry about any current or prospective application) or by contacting or corresponding with us by phone, e-mail or otherwise. The information which you may give us may include your name, address, e-mail address and phone number, bank and debit card information and other financial information.
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
- Information which we receive from other sources. We may receive information about you if you make an enquiry about or apply for a loan or guarantee with us or use any the other services which we provide. In this case, we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site. We also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, fraud prevention agencies and credit reference agencies – please see below for details as to how we deal with fraud prevention agencies and credit reference agencies and the circumstances in which information about you will be disclosed to them) and may receive information about you from them.
- Fraud Prevention Agencies. In the event that you provide us with false or inaccurate information, and we have reasonable grounds to suspect fraud, we may share your information with a fraud prevention agency to create a digital footprint based on all available information associated with any attempt to commit fraud. Any information disclosed to a fraud prevention agency may be used by them for statistical analysis and disclosed to other organisations to prevent any further fraud or attempted fraud.
- Credit Reference Agencies. We use credit reference agencies to help build a better understanding of your financial circumstances, but the information which they provide to us alone does not determine your eligibility (or otherwise) for a loan from us or our accepting you as a guarantor. The information which we collect from credit reference agencies relating to you is for our own use only. We will notify credit reference agencies of any default of your obligations under any such contract with us and/or your loan or guarantee being referred for legal collection. We only use UK-based credit and fraud agencies and do not disclose any of your information to any third party companies outside the United Kingdom or otherwise in a manner which does not comply with the GDPR and DPA.
The identities of the CRAs, their role as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail within the Credit Reference Agency Information Notice (CRAIN).
- This notice is accessible from each of the three CRA links below:
- Callcredit www.callcredit.co.uk/crain
- Equifax www.equifax.co.uk/crain.html
- Experian www.experian.co.uk/crain/index.htm
Please note that we record telephone calls which we make to or receive from you for your protection and for the purposes of staff training, including quality control. Any recordings of calls made to you or received from you are only accessible by a dedicated and assigned member of staff, and under appropriate supervision. Please note that by contacting us by telephone, you confirm your consent to any such call being recorded for these purposes.
How we use your personal data
We use personal data held about you in the following ways:
- Information which you give to us. We will use this information:
- to make, or assist in making, credit decisions about you and assess any lending to you or guarantee from you;
- to carry out our obligations arising from any contracts entered into between you and us (including, without limitation in relation to a personal loan or other financial product), to provide you with the information, products and services that you request from us;
- to identify, prevent, detect or deal with fraud, money laundering or other criminal activity and to recover any debts which you may owe to us;
- to provide you with information about other products and services we offer which are similar to those that you have already purchased or enquired about and to develop or improve our products and services;
- to communicate with you in relation to any application or enquiry for any of our products or services, and to notify you about changes to our products and services;
- to carry out audits, market research, business and statistical analysis; and
- to ensure that content from our site is presented in the most effective manner for you and for your device.
- Information which we collect about you when you visit our site. We will use this information:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our 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
- to make suggestions and recommendations to you and other users of our site about products or services that may interest you or them.
- Information which we receive from other sources. We may combine this information with information which you give to us and information which we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
When we may share or disclose your personal data
We may share your personal data with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may share your information with selected third parties including:
- Business partners, suppliers and sub-contractors for the performance of any contract which we may enter into with them or you;
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience;
- Analytics and search engine providers that assist us in the improvement and optimisation of our site;
- Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you, and subject to the details set out above upon how we deal with them.
We may also disclose your personal data to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- If we, or substantially all of our assets, are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; and
- 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 terms and conditions and other agreements, or to protect our rights, property, or safety of our customers and/or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Please note that we operate on the basis that any information regarding the details of any contract relating to our products and services can only be divulged to you as a customer and/or guarantor unless you inform us otherwise or in the event of any valid power of attorney subsisting between you and a third party and/or relative.
Security of your personal data
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, to apply for any of our products or services and to check on the status of an application, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we always will do our best to protect your personal data and to comply with our security obligations pursuant to the Act, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We hold personal information for the duration of your loan agreement with us and for a period of 7 years thereafter to meet our statutory and regulatory requirements.
The GDPR and DPA provide the following rights for individuals:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling.
Here we briefly explain what these are in the context of 1Plus1 Loans Limited.
This Privacy Statement and our application and loan documentation explain the collection and use of your personal data, including our purposes for processing your personal data, our retention periods for that personal data, and who it will be shared with.
Accessing, correcting and deleting your information
You have the right to access the personal information we hold on you by writing to us at the address provided in this Privacy Statement. You also have the right to have your data corrected if it is inaccurate or incomplete, and if we have no legal or legitimate justification in retaining your data, you may have a right to request its deletion or to restrict us from processing your information if it is incorrect or no longer required. However, there may be legal reasons as to why we may need to keep your data.
Right to object
You have a right to object to the processing of your information in cases where we do not have legitimate grounds for processing your personal data.
You have the right to ask us to provide you with a copy of the personal information you provided to us or to request that we transfer this data to another organisation in a format that can be easily re-used.
You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by checking the relevant box on the loan document before you sign it. You can also exercise the right at any time by contacting us.
Automated decision making and profiling
When we collect your personal information either directly from you or from other authorised sources, we may use systems to make automated decisions.
The types of automated decisions we make are:
- Pricing – We sometimes make decisions on the cost of the product and services you have applied for based on the information we have collected
- Approving Credit – Once you submit an application for finance, we may make automated decisions to establish whether we can offer you our products and services and to proceed with your application
- This decision is based on our credit scoring models which assess how likely you are to act while paying back any funds borrowed. This assessment will check on how you have paid similar accounts in the past
Our credit scoring model uses three sources to ensure a fair and well informed outcome is achieved;
- The details you submit on your application form
- Information held and supplied from credit reference agencies
- Any data that we may already hold that relates to you
You can ask us not to make our decision based on automated means alone and you can object to an automated decision and request that we review your application manually.
What to do if you wish to make a complaint
If you are unhappy with how we have processed your personal information, please contact us.
You also have the right to make a complaint to the Information Commissioner’s Office (‘ICO’), which regulates the processing of personal data in the UK. You can do this by phone on 0303 123 1113, or via the ICO website. https://ico.org.uk/
1Plus1 Loans Limited,
The Old Tannery,
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Changes to this policy
Last modified: 12th May 2018