What we will do when you apply
• Before we can supply you with services, goods or financing, we need to collect and process your personal information or ‘data’ so we can decide if we can accept you as a customer.
• We process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested.
• We’ll take appropriate steps to make sure the personal information we hold on record for you is accurate. If at any point you believe the personal information we are holding and processing for you is incorrect, you can request to see this information, and have it corrected or deleted.
• If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter. If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law, you can complain to the Information Commissioner’s Office (ICO).
• Further details of the ways we collect and use your personal information is also provided in the credit agreement which is to be read in conjunction with this Use of Your Personal Information Notice.
• We give you choices about the ways we use and share your personal information, and we’ll respect the choices you make.
Use of your personal data
- All the personal data we hold about you will be processed by our staff in the United Kingdom. However, please be aware that your information may be stored on a cloud-based system with servers located within the European Union.
- We will only collect as much information as we need for specific, identified purposes, and we won’t use it for any other purposes without obtaining your consent.
- We will collect the following types of information about you; name, date of birth email address, mailing address, phone number, employer name, take-home pay, and banking information (such as bank routing number, debit card number and account number).
- Please see the following list of types and times when we will collect information from you:
- information collected directly from you through your online application, information collected through online forms or entries on our lead providers', and/or associated group companies’ websites, or information you provide when you contact our customer services department
- your telephone, email or other electronic communications with us (for example when speaking to our Customer Services Team), which may be monitored and recorded
- information about your health or mental capacity. This information will be held so that we can comply with our obligations to you
- information about your transactions including loan balances
- information from outside sources such as credit reference agencies and customer service providers regarding credit worthiness and credit history
- information about your visits to our website, and information we collect when you use the website
- information about you when you use our feedback form
- information regarding your questions about our programmes with associated group companies
- Information at credit reference and fraud prevention agencies and that of your ‘financial associate’ if you have one, i.e. a person with whom you have, or have had, joint personal financial arrangements such as joint accounts or have made joint credit applications. It may be your spouse or partner (not a business partner). We may also, in certain limited circumstances, check the record, including credit details, of other members of your family and, if you are a director or partner in a small business, we may also check on your business or seek information from your employer
- If you tell us that you have a financial associate, we will search link and record information about you both at credit reference and fraud prevention agencies. You must be sure you have your financial associate’s agreement to disclose their information.
- We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.
- As part of the processing of your personal data, decisions may be made by automated means. This means we may automatically decide that you pose a fraud or money laundering risk if our processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct; or is inconsistent with your previous submissions; or you appear to have deliberately hidden your true identity. If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services and financing you have requested, or we may stop providing existing services to you. You have rights in relation to automated decision making: if you want to know more please contact us using the details provided later in this notice.
- We will add to your record with the credit reference agencies details of your Agreement with us, the payments you make under it, any default or failure to keep its terms and any change of name or address.
- Account information given to credit reference agencies remains on file for 6 years after the account is closed, whether settled by you or upon default, except where we legitimately believe a longer period is necessary.
- If we have reasonable grounds to believe that our asset is at risk, we may conduct credit reference agency, motor insurance database and fraud prevention agency searches, to confirm or establish your contact details, insurance cover, and to assess or manage our risk.
- We may pass your personal information to local authorities, councils, or other similar local government agencies in pursuing their or our legitimate interests.
- The personal information we hold about you will be disclosed to our funders and may be disclosed by them to their funders, and in each case to their professional advisors. It may also be used for statistical analysis, testing, marketing and training purposes, both internally and externally.
- We may also request that you provide details of individuals who are able to act as referees on your behalf by verifying some of the personal information you provide about yourself. The information we collect about these third parties may include their name, address, and phone number.
How we and others may use and share your information
- We use your personal information for the following purposes:
- in the normal course of our business to provide you with the services or products you request such as processing loan transactions and updating your account records
- to contact third parties, such as your employer, who you have nominated to verify information about yourself
- to enhance your experience of using our website or our services
- for conducting statistical analysis
- to identify you when you contact us or visit our website, and to prevent and detect fraud or money laundering. This may involve the use of voice detection technology to analyse recordings of your telephone calls with us
- to identify which of our products might interest you
- for other regulatory checks including credit assessment
- to produce aggregated information about customers for editorial or feedback purposes for our advertisers.
- Whether or not your application with us proceeds, the credit reference agencies will place a record of our search on your credit file. This record (but not our name) will be seen by other organisations when you apply for credit in the future. A large number of applications within a short period of time could affect your ability to obtain credit
- The agencies will link your records and those of your financial associate(s), including any previous and subsequent names. These links will remain on your and their files until you or they tell the agency you are no longer financially linked, and the agency accepts this.
- The agencies supply us with credit information, such as previous applications, the conduct of accounts in your and your financial associate(s) name, any business accounts you have, fraud prevention information and public information such as County Court Judgments, bankruptcies and the Electoral Register entries.
- Whether or not your application with us proceeds, a record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you.
- Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.
- We will request that information held by credit reference and fraud prevention agencies, other industry participants and the Motor Insurance Database be disclosed to us and other organisations to, for example:
- prevent fraud and money laundering, for example by checking details on applications for credit and credit-related or other facilities, proposals and claims for all types of insurance and job applications and employee records
- recover debts that you owe and trace your and the goods whereabouts
- manage credit accounts and other facilities
- verify your identity
- make decisions on credit, insurance and other facilities about you, your financial associate(s), members of your household or your business
- carry out statistical analysis to help with decisions about credit and account management
- assess that the vehicle you have agreed to purchase from us pursuant to the terms of the agreement is fully insured under a comprehensive insurance policy.
- We will also share the personal information you submit with our associated group companies (which includes any company linked to us in some way by common ownership or management) for the purposes of: (a) the provision of products and service you request and (b) consumer profiling and market research. A list of associated companies is available on request by contacting us directly via the contact details provided below.
- We will share your information with our associated group companies for the following administrative activities:
- Managing your relationship with us and notifying you of any changes to those products
- Responding to your queries and complaints
- Administering offers, competitions and promotions
- Undertaking affordability reviews
- Updating, consolidating and improving the accuracy of our records
- In addition, we will share your information with our associated group companies for the following data usage:
- Transactional analysis
- Arrears and debt recovery and debt sale activities
- Crime detection, prevention and prosecution
- To evaluate the effectiveness of marketing, and for market research and training
- To support customer modelling, statistical and trend analysis, with the aim of developing and improving products and services
- To enable assessment of lending risks
- By sharing this information, it enables our companies to better understand your needs and run your account(s) in the efficient way you expect.
- We will share your personal information with third parties under the following circumstances:
- with lenders, credit reference agencies, customer service providers and collection agencies. We have trusted relationships with these carefully selected third parties who perform services on our behalf. All service providers are bound by contract to maintain the security of your personal information. Credit reference agencies may add to their records about you, information about our search of their records and your application with us, and this will be seen by other organisations that make searches
- with a purchaser, in the event our business or all its assets are acquired by a third party (in which case personal information held about customers will be one of the transferred assets)
- to enforce any of our terms and conditions
- with fraud prevention or law enforcement agencies, in the event false or inaccurate information is provided and fraud or money laundering is identified. We and other organisations will also access and use this information to prevent fraud and money laundering, for example when checking details on applications for credit and credit related and other facilities, managing credit and credit-related accounts or other facilities, recovering debt, checking details on proposals and claims for all types of insurance, and checking details of job applicants and employees
- with individuals who you nominate as your referees to verify certain information that you provide to us
- if required or compelled to do so by any legal authority, as required by law or when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on us
- with other third-party service providers, who act as agents to perform tasks on behalf of and under the instructions of Moneybarn. These service providers must agree to use personal information only for the purposes for which they have been engaged by us and must either: (1) comply with mechanisms permitted by the European data protection law(s) for transfers and processing of personal information (including contractual obligation under the EU model clauses); or (3) agree to provide adequate protections for the personal information that are no less protective than those set forth in this notice.
- Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.
- We will also share your information with local authorities, councils, government and law enforcement agencies if a formal request is received. The use of your data by any of these parties will be governed by data protection and other relevant laws.
- Information held and obtained by us in relation to you will be passed to our agents for the purposes of taking enforcement action against you and/or a third party pursuant to our rights under the Agreement.
We will also pass your details and information obtained on you if we transfer/assign our rights and duties in this Agreement to the transferee and/or its professional advisors, and may do so in advance of any transfer to assist in preparation for a transfer.
- We will share your information with your bank and other agencies to the extent necessary, and to perform checks for the prevention of fraud, to verify your banking details, and to validate your identification.
How long we keep your personal data
More information about your rights
You have the following rights with respect to your personal data:
- The right to access information we hold on you.
- At any point you can contact us to request the information we hold on you, including details of why we have that information, who has access to the information, and where we obtained the information from. Once we receive your request we will respond within one calendar month.
- There are no fees or charges for the first request but additional requests for the same data may be subject to an administrative fee of £25 per request.
- The right to correct and update the information we hold on you.
- If the data we hold on you is out of date, incomplete or incorrect, you can inform us, and we will update your data.
- The right to have your information erased.
- If you feel we should no longer be using your data or that we are illegally using your data, you can request us to erase some or all the data we hold for you.
- When we receive your request, we will confirm whether the data has been deleted or explain the reason why it cannot be deleted (for example we will need to keep the data because we have a legitimate interest or to comply with regulations).
- The right to object to processing of your data.
- You have the right to request that we stop processing your data. When we receive your request, we will confirm if we are able to comply or explain why we have legitimate grounds to continue processing your data. Even after you exercise your right to object, we will continue to hold your data to comply with your other rights or to bring or defend legal claims.
- Right to restrict processing
- In some circumstances, you can ask us to restrict how we use your personal data. Your rights are set out within Article 18 of the GDPR, and if you need more information you can contact us using the details provided later in this notice. This is not an absolute right, and your personal data may still be processed where certain grounds exist. This is: With your consent; For the establishment, exercise, or defence of legal claims; For the protection of the rights of another natural or legal person; For reasons of important public interest. Only one of these grounds needs to be demonstrated to continue data processing. We will consider and respond to any requests we receive, including assessing the applicability of these exemptions.
- The right to data portability.
- You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within one month of receiving your request.
- The right to withdraw your consent for us to hold, process or share your data, where we sought your consent to collect and use it.
- You can withdraw your consent easily by telephone, email, or by post (see the contact details provided later in this notice).
- The right to lodge a complaint with the Information Commissioner’s Office (org.uk/concerns)
When exercising any of the rights listed above, to process your request we will need to verify your identity for your security.
Alternatively, please contact our Data Protection Officer by emailing DPO@moneybarn.com or you can write to us at this address: Data Protection Officer – Moneybarn, The New Barn, Bedford Road, Petersfield, Hampshire, GU32 3LJ
If you consent to direct marketing via the opt-in process, we will contact you by post, email, telephone or mobile text and/or messaging service (SMS) about Moneybarn products or services we have available which we think are relevant to you. You have a legal right to prevent your information being used for direct marketing purposes. If you do not want your information to be used for these marketing purposes, you can opt out by calling our Customer Services Team on 0330 555 1230, or by emailing firstname.lastname@example.org or you can write to us at: Moneybarn, The New Barn, Bedford Road, Petersfield GU32 3LJ.