Use of Third Party Bank Account Aggregation Services
Who are we?
If you have any questions or concerns about how we collect, store and use your information, you may contact us by telephoning 020 8988 0627, by e-mailing us at firstname.lastname@example.org or writing to us at Fair Finance, 18 Ashwin St, Dalston, London, E8 3DL.
The legal stuff
We will at all times only collect and process your personal information in accordance with the Data Protection Act 1998, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any other applicable data protection legislation.
What information do we collect and how do we collect it?
When you use the Website or provide us with information by post, online applications, telephone, fax, e-mail, SMS or in person, we may collect, store and use certain business or personal information that you disclose to us. The information that we may collect from you includes your name, address, gender, telephone, mobile contact details, National Insurance number, marital status, number of dependants, e-mail, job details, financial details, and any other information you provide to us in connection with your loan application or for monitoring purposes. When your visit our Website, we may also collect details of your computer’s internet protocol address, which is automatically collected by our web server, and other information about your use of the Website, such as log-in, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. We also collect standard internet log information and details of visitor behaviour patterns, in order to find out things such as the number of visitors to the various parts of the site and we study these patterns in a way which does not identify anyone. Finally, we may receive information about you from third parties (such as credit reference agencies (see below) and bank data aggregation suppliers (see here)) who are legally entitled to disclose that information or where you provide your consent.
How do we use your information?
By using the Website or using any of our financial products or services, you agree that your business or personal information may be used by us and by carefully selected third parties chosen by us for any of the following purposes:
- (1.1.a) to provide you with a personalised browsing experience when using the Website;
- (1.1.b) internally assessing your loan application and administering your loan;
- (1.1.c) using credit reference and fraud prevention agencies to help us make credit decisions where you apply for a loan (as described below);
- (1.1.d) carrying out director searches and other relevant searches on all directors of your business in order to process your loan application;
- (1.1.e) contacting your suppliers using the information you have provided in connection with your loan application to obtain a reference for your business;
- (1.1.f) to send you details (including by post, phone, e-mail or SMS) about our products and services, so long as you have not opted out of this;
- (1.1.g) to share the outcome of your application to anyone who introduced you to us;
- (1.1.h) to share any information you have passed to us in relation to your application to anyone who introduced you to us, where you have consented to this;
- (1.1.i) as a case study in marketing material relating to our products or services. We may publish this on our blog, website, social media or through other channels, where you have consented to this;
- (1.1.j) for statistical, monitoring or market research purposes and for creating reports;
- (1.1.k) to fulfil any other contractual agreements between you and us;
- (1.1.l) for fraud detection and prevention’s purposes; and
- (1.1.m) to aggregate it with other applicant information to value our loan portfolio and inform our policies on lending; and
- (1.1.n) to comply with legal and regulatory requirements.
We may disclose your personal information to any member of our group, which means our group companies, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
If we (i) transfer, charge, disclose or assign your agreement to a third party, including in connection with the sale, transfer or disposal of our business, (ii) employ a third party to manage any aspect of your account, or (iii) engage a third party in relation to your loan application for any other reason, we may pass relevant information about you to them.
We may share your information where 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 contracts with you.
We may also share your information with credit reference and fraud prevention agencies, as explained further below.
We may share your information with our suppliers of processing services. This will include bank data aggregation suppliers, where you consent.
In addition, we (or third parties acting on our behalf) may also store or process information that we collect about you in countries outside the European Economic Area, which may have lower standards of data protection, provided there are appropriate safeguards in place.
We have put in place technical and organisational security measures to prevent the loss or unauthorised access of your personal information. However, whilst we have used our best efforts to ensure the security of your data, please be aware that we cannot guarantee the security of information transmitted over the Internet.
Credit Reference Agencies (CRAs) and Fraud Prevention Agencies (FPAs)
By applying for loans with Fair Finance, you agree that we may use your personal information to make credit reference checks and for fraud checking and prevention purposes. We currently use Call Credit and Experian as our CRAs.
In order to process your application we will supply your personal information to these 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. We do this to assess creditworthiness and product suitability, verify the accuracy of the data you have provided to us, check your identity, manage your account, trace and recover debts and prevent criminal activity (including fraud and money laundering), and ensure that any offers provided to you are appropriate to your circumstances.
In considering your loan application we will search your record with us and at CRAs. We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time.
CRAs will share your information with other organisations.
Your record may be linked to your spouse/partner, any joint applicant or other person with whom you are linked financially (“associated records”) in which event you will be assessed with reference to associated records. Please be sure that you have discussed this with them and shared 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.
Our search will create “a search footprint”. CRAs provide us with both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information. They will add to their record about you, details of our search and your application and, where relevant, the name and address of your business and its proprietors. This will be seen by other organisations that make searches and, together with other information about you and those with whom you are linked financially, may be used to make credit decisions about you and those with whom you are linked financially. If you are a director we will seek confirmation from the CRA that the residential address provided is the same as that shown on the restricted register of directors’ usual addresses at Companies House. We may use a credit scoring or other automated decision making system.
We will add to your record with CRAs details of your agreement with us, any payments you make under it and any default or failure to keep to its terms. Records remain on file for 6 years after they are closed, whether you settled the debt or defaulted.
It is important that you provide us with accurate information. We may check your details with FPAs. If false or inaccurate information is provided and fraud is identified, details will be passed to FPAs and other organisations to prevent fraud and money laundering. These records will be shared with other organisations and may be used and searched by us and them, for example, to consider applications for credit and credit related services, or other facilities, for you and any associated person; check details on proposals and claims for all types of insurance; trace debtors, recover debts and manage your account(s); check details of job applicants and employees. Law enforcement agencies may access and use this information. We may make periodic searches at CRAs and FPAs to manage your account with us. We and other organisations may access and use from other countries the information recorded by CRAs and FPAs. Where any search or application is completed or agreement entered into involving joint parties, you both consent to our recording details at CRAs. As a result an ‘association’ will be created which will link your financial records and your associate’s information may be taken into account when a future search is made by us or another lender unless you file a “disassociation” at the CRAs.
You can contact the CRAs currently operating in the UK; the information they hold may not be the same so it is worth contacting them all. Please contact us at the telephone number, e-mail address or postal address provided above if you want to have details of the CRAs or any FPAs from whom we obtain, and to whom we pass, information about you or if you would like to read the full details of how the information held by them may be used. You have a legal right to these details. You are entitled to a copy of the information we hold about you by writing to us and requesting it.
The identities of the CRAs, their role also 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 here.
When completing a loan application, you confirm that the information and evidence that you have provided in support of this application is correct and may be used in the ways described above. You hereby authorise Fair Finance to make any enquiries it deems necessary to third parties in connection with your application. You understand that if there is any change in your circumstances you must advise Fair Finance immediately. You confirm that Fair Finance may disclose any of the details or supporting evidence you have provided in connection with your application and copies of any correspondence or agreements between us with third parties, such as third party funders.
What are your rights?
You have the right to contact us in order to request a copy of the information we hold about you (please note that a £10 fee may be payable) or to access, cancel or correct any information that we hold about you. If you object to us using your personal information in any way, please let us know in writing.
You are able to withdraw any and/or all consent that you have provided regarding our collection and processing of your personal data at any time. You can do this either by calling 0207 8988 0627, sending an email, sending us a message via our website, sending a letter to our office at: Fair Finance, 18 Ashwin Street, E8 3DL, or by approaching a member of staff at one of our branches. Please ensure that you detail which aspects of the consent you have provided you wish to update in your communication with us.
You have the right to be forgotten, in certain circumstances you can ask for the data we hold about you to be erased from our records.
You have the right of portability, you have the right to have the data we hold about you transferred to another organisation.
If you are not happy with how we have record or process any of your data please tell us using any of the methods of communication noted above. You also have the right to direct a complaint to the Information Commissioner’s Office. Details of how to do this can be found on their website.
You may also contact us by any of the means listed above to inform us if you do not wish to receive any marketing materials from us.
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