Privacy policy

4.1 Purposes for which we will use your personal data

We have set out below a description of the ways we plan to use your personal data, the purposes for this usage and which of the legal grounds we rely on to do so. We have also identified what our Legitimate Interests are where appropriate. Note that we may process your personal data for more than one legal ground depending on the specific purpose for which we are using your data. If you had a loan product or are supporting our customers (e.g. powers of attorney) then the reasons we process your personal data are set out separately below.

Purposes and Legal Grounds

1. We may process your information to:
   1. Understand how you use products, services, processes and related customer experiences provided by us and other organisations;
   2. Inform the way that we manage our products, services, processes and platforms;
   3. Develop, test and change our products, services, processes and platforms;
   4. Monitor usage and performance of our products, services, processes and platforms; perform analysis (e.g. statistical, market, product analysis), reporting, forecasting and accounting;
   5. Tell you about our products, services, events and activities that may be of interest to you;
   6. Understand how you interact with our marketing; develop, test or change our marketing activities;
   7. Communicate with our third parties to help them understand, improve and fulfil on marketing activities (including supporting behavioural advertising techniques e.g. use of cookie data);
   8. Promote our products and services.

   When processing your information for these purposes, we are relying on our Legitimate Interest to help us understand, develop, improve and market our products and services.

2. We may process your information to:
   1. Allow you to begin using or register for our products or services;
   2. Check your eligibility for our credit products; process your application and/or set up an account for you;
   3. Uphold our lending criteria by performing creditworthiness, affordability and other checks including, but not limited to, fraud checks, anti-money laundering checks, vulnerability assessments, identity checks;
   4. Report activities to credit reference agencies (CRAs), fraud prevention agencies (FPAs) and/or crime prevention agencies in line with our legal, regulatory or business requirements;
   5. Communicate with you to provide updates following a credit application or eligibility check;
   6. Communicate with you to provide updates and information while you are using, registering or continuing to use one of our products or services;
   7. Communicate with you for design or research purposes or to ask you about our current or potential products, services, processes and customer experiences.
   8. Provide targeted support communications via social media platforms (for example Facebook), by sending to them a hashed version of your personal information (which may be your email address, phone number and/or firstname and surname) to provide you with information in relation to our current service availability and other relevant financial industry service and support information.

   When processing your information for these purposes, we rely on our Legitimate Interest to allow you to access our products and services. In addition, in relation to some of the purposes, it is necessary for us to process your information for the Performance of the Contract between us.

3. We may process your information to:
   1. Enable you to access and use our online services and functionality;
   2. Understand how you use and navigate our online services;
   3. Tailor online experiences or develop and/or change these services;
   4. Service and fulfil on your products and services (e.g. processing transactions, managing account information and settings);
   5. Provide you with other suitable products, services or relevant information where we (or our partners) think you may be interested;
   6. Manage potential Payment Protection Insurance (PPI) related activities on your accounts including activities relating to the potential miss-sell of PPI;
   7. Keep our records up to date including updating preferences and making changes to your account;
   8. Manage requests from you where you are exercising your data privacy rights;
   9. Assess your personal circumstances while you are using our products and services and, potentially, taking actions on your account based on these circumstances (e.g. making changes to your account where you appear to be in financial difficulty);
   10. Communicate with you for any purpose relating to the servicing of your account;
   11. Manage your accounts, products or services effectively (e.g. applying credit limit increases and decreases, updating your product terms);
   12. Develop, improve or change the products and services that you are using;
   13. Offer you additional products, services and promotions;
   14. Assess, collect or recover outstanding debts from you;
   15. Transfer ownership of your account to a third party. This may include activities we carry out with third parties including the assessment, pricing and handover of the debt;
   16. Inform strategies around how we collect, recover or sell outstanding debts. This may involve sharing data with third parties to help inform this strategy including which third parties we work with;
   17. Monitor usage and performance of our products, services, processes and platforms; perform analysis (e.g. statistical, market, product analysis), reporting, forecasting and accounting.

   When processing your information for these purposes, we rely on our Legitimate Interest to fulfil on our products and services. In addition, in relation to some of the purposes, it is necessary for us to process your information for the Performance of the Contract between us.

4. We may process your information to:
   1. Perform checks to prevent, detect, investigate and report fraud, crime and/or terrorist activity;
   2. Carry out our obligations required by relevant laws and regulation including anti-money laundering (AML) checks, Her Majesty's Treasury (HM Treasury) and Office of Foreign Assets Control (OFAC) sanctions list checks, Politically Exposed Persons (PEP's) assessments and Transaction/Account monitoring and restriction;
   3. Protect the security and resilience of our networks/applications and respond to technical and security incidents;
   4. Devise defence strategies (e.g. in relation to fraud, crime, terrorist or cyber-attack risks) and develop, test or change our defences.
   5. Review and take appropriate action relating to threatening and abusive behaviour of customers to our agents whilst performing their day to day role.
   6. To ensure we are able to offer our services in a secure manner by authenticating our customers and reducing the risk of fraud.

   When processing your information for these purposes, we rely on our Legitimate Interest to manage risk, security and crime prevention. In addition, in relation to some of the purposes, we may process your information to comply with a Legal Obligation.

5. We may process your information to:
   1. Improve, test, investigate and remediate any issues with our internal processes and practices;
   2. Maintain your data and ensure the data that we hold about you is accurate and up to date.

   When processing your information for these purposes, we rely on our Legitimate Interest to manage and improve our business processes

6. We may process your information to:
   1. Cooperate with (and respond to) requests from courts, regulators, law enforcement bodies and other institutions (e.g. fraud prevention agencies);
   2. Appropriately handle and process complaints or disputes – this may include contacting relevant parties;
   3. Exercise our rights in relation to complaints, disputes or litigation;
   4. Manage policy affairs, public relations issues, media enquiries or customer interactions with the media;
   5. Manage complaints with third parties;
   6. Manage disputes and charge backs;
   7. Manage litigation against third parties;
   8. Enable us to provide legal and/or regulatory advice in line with our business activities;
   9. Share your online account information with regulated third parties, known as Account Information Service Providers (AISPs) where you have asked them to access this information.

   When processing your information for these purposes, we rely on our Legitimate Interest to satisfy our industry, regulatory and legal requirements and exercise our rights. In addition, in relation to some of the purposes, we may process your information to comply with a Legal Obligation or it may be necessary to assist in relation to a task performed in the Public Interest.

We may use third parties for any of the purposes listed above.

Loan customers and those supporting our customers

If you had a loan product or are supporting one of our customers (e.g. powers of attorney) then we only process your data for the specific purposes set out below:

Special Categories of Personal Data

Health data
When we receive information concerning your health from you or someone else we may process it to provide a more appropriate service and/or protect your best interests as follows:

1. Processing personal data relating to your health enables us or someone else to better protect you against potential harm, such as:
   • Taking out credit that is not appropriate;
   • Falling behind on debt repayments;
   • Falling prey to fraud or financial abuse; or
   • Otherwise not being able to protect your economic well-being
2. To ensure that we are able to send communications to you in an appropriate format or make other reasonable adjustments due to a condition.
3. So that we can try and prevent fraud and/or where there may be suspicions of terrorist financing or money laundering;

We may also process your health data to establish, exercise or defend a legal claim.

Where we process this information we will usually do so on the basis of a Substantial Public Interest which has been set out in legislation, to perform or exercise obligations or rights which are imposed or conferred by law on us in connection with social protection or to exercise, establish or defend a legal claim.

If you do not want us to process information concerning your health, you may object to this processing as set out in Your legal rights. We will consider your request appropriately. If we stop processing your health data, we may still include a marker on your account to ensure that we are able to continue to protect your best interests.

Biometric Data

To ensure we are able to offer our services in a secure manner by authenticating our customers and reducing the risk of fraud, we process information about operations and behaviour performed on the device such as mouse movements and key strokes (Device Operations). In some circumstances this information is known as Biometric Data - where it is used to uniquely identify you.

Where we process this information we do so on the basis of a Substantial Public Interest which has been set out in legislation.

If you do not want us to process this information you may object to this processing as set out in Your Legal Rights. We will consider your request appropriately. If we stop processing this information, we will still need to protect the security of your account. We will do this in alternative ways available to us but this might change the overall standard of security that we can apply. You also might not be able to access your account and/or carry out transactions as quickly or easily.

We use third parties to fulfil this purpose on our behalf. The third parties do not process these data as Biometric Data but only as Device Operations. They will:

• Use the Device Operations data to help us to understand whether you are the person using your device;
• Maintain the confidentiality and security of the information, including maintaining technical and physical safeguards that are designed to (a) protect the security and integrity of the information while it is within their systems and (b) guard against the accidental or unauthorised access, use, alteration or disclosure of information within their systems;
• Only retain the data for as long as is necessary to fulfil this purpose and delete once it is no longer needed for this purpose.

They will not:

• Share the information with any third parties.
• Use the information to append to other information to build profiles.
• Use the information to provide services to you.

4.2 Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

You will receive marketing communications from us if you have requested information from us or provided us with your details when you applied or registered for one of our products or services and, in each case, you have not opted out of receiving that marketing. However, you can ask us to stop sending you direct marketing at any time. When you ask us to stop, please note that this may not take effect immediately, since it takes time for the change to be processed in our systems.

If you ask us to stop sending you marketing messages, you will still receive communications pertaining to the servicing or fulfilment of your account, product, service or relationship with us (such as statements for your credit product, communications about your outstanding debts or relevant updates about the products or services that you are already using).

We may also use third parties to conduct marketing activities on our behalf.

4.3 Cookies and Online Marketing

For more information about the cookies we use for online marketing purposes, please see our Cookie and Online Marketing Policy.

We share information that we collect about you such as email addresses and telephone numbers with our third party partners such as Facebook, Google, Microsoft and Yahoo. We do this so that we can identify groups of similar audiences to target for advertising purposes, to display relevant advertisements to you or ensure you do not see advertisements that are not relevant. We call these groups 'custom audiences'.

Yahoo

You can find more information about how Yahoo uses data that it receives here:

https://legal.yahoo.com/us/en/yahoo/privacy/index.html  opens in a new tab

Microsoft

You can find more information about how Microsoft uses data that it receives here:

https://privacy.microsoft.com/en-gb/privacystatement  opens in a new tab

Google

You can find more information about how Google uses data that it receives here:

https://policies.google.com/technologies/partner-sites  opens in a new tab

Facebook Custom Audience

Facebook Custom Audience feature enables Facebook to create an audience using users' data such as email address, name, date of birth and contact details enabling us to display relevant advertisements to you, identify groups of similar audiences to target for advertising purposes or ensure you do not see advertisements that are not relevant. When we use this feature, we “hash” your data locally before we pass it to Facebook. This is a process which turns your data into letters and numbers so that it is protected. If you have opted out of receiving marketing, your personal data will not be shared with Facebook. You can opt out of marketing at any time by contacting us. If you opt out of marketing after your data has been shared with Facebook, your data will be removed from the custom audience.

Facebook will:

• use the hashed data for matching purposes and
• maintain the confidentiality and security of the hashed data and the collection of Facebook User IDs that comprise the customer audience created from the hashed data, including maintaining technical and physical safeguards that are designed to (a) protect the security and integrity of data while it is within Facebook's systems and (b) guard against the accidental or unauthorised access, use, alteration or disclosure of data within Facebook's systems

Facebook will not:

• share the hashed data with third parties or other advertisers and will delete the hashed data promptly after the match process is complete;
• give access to or information about the custom audience(s) to third parties or other advertisers;
• use custom audience(s) to append to the information it has about its users or build interest-based profiles;
• use custom audience(s) to provide services to you.

For further details in relation to Facebook Custom Audience, please visit https://www.facebook.com/legal/terms/customaudience  opens in a new tab .

Where we send data to Facebook, we are a Joint Controller with Facebook. This Joint Controller relationship is subject to Facebook’s Controller Addendum  opens in a new tab . Facebook is the independent Data Controller once it is in receipt of that data. You can find more information about Facebook's processing at https://www.facebook.com/policy.php  opens in a new tab

When processing your information for these purposes, except for targeting advertising directly to you (the lawful basis for which is explained below) we are relying on our Legitimate Interest to help us understand, develop, improve and market our products and services.

When processing and sharing your data in order to display relevant advertisements to you directly, we will only do so where we have obtained your explicit consent.

4.4 Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal ground which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Making Lending Decisions

For our credit products, we use automated decision making when deciding whether to lend money to you and to determine the initial setup for our products (e.g. what credit limit you will be offered on your credit card). When you have an account with us, we may continue to use automated decision making where deciding whether to offer you additional credit (e.g. where offering you a credit limit increase).

Where making assessments of this type, we may use a technique known as "credit scoring".

Credit scoring uses data from several sources:

• information you have provided;
• information we may collect or already hold about you; and
• information provided by third parties (including credit reference agencies)

We use data from these sources and our logic to predict behaviours (e.g. how well we expect you to manage your product and make regular payments), to group our customers (or potential customers) into 'customer segments' and to make our lending decisions (e.g. which applicants do we accept / decline).

This approach allows us to make quick, consistent decisions, uphold our lending requirements and ensure that we lend responsibly. These automated decisions may lead to your credit application being declined and may limit your ability to access further credit in the future.

Detecting Fraud

Where you apply for (or register for) one of our products or services, we use automated processes to detect and help prevent fraud.

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.

We may also continue to monitor your accounts, your product usage and your transactions to determine whether your account is being used for fraudulent activities.

We utilise data from several sources to help us identify fraud risks:

• information you have provided;
• information we may collect or already hold about you; and
• information provided by third parties (including fraud prevention agencies)

We combine data from these sources and defined logic to identify threats and prevent fraud losses. If we think there is a risk of fraud, we may stop activity on your account and/or refuse access.

Providing you with access to products and services

When you apply (or register) for one of our products or services, we perform checks to ensure that these are suitable for your circumstances and that we manage our business risks.

To do so, we utilise data from several sources:

• information you have provided;
• information we may collect or already hold about you; and
• information provided by third parties.

These checks may include (but are not limited to):

• checks to ensure you meet conditions for opening an account (e.g. checking your age and residence);
• checks based on your existing products with us (e.g. checking whether you already have an account with us and how it is currently being managed);
• checks to identify money laundering, criminal / terrorist activity or cyber security threats that may pose a risk to you and our business.

Where we identify circumstances or threats that introduce a risk to you or our business, we may not be able to provide you with access to our products or services.

Managing, tailoring and marketing our products and services

Where we have an existing relationship with you, we may use profiling and automated decision making to help manage this relationship. We use these techniques to ensure that we manage your accounts, products or services appropriately; help you get the best out of your products and services; and provide you with promotions or offers that we think you will be interested in.

We use data that you provide along with internal and third-party data to place you into groups with similar types of people. We call these groupings 'segments' and these are used to help us understand, test and tailor our products, services and marketing more appropriately depending on identified segment types. Some examples of how we use profiling and decision making are:

• Optimising and fulfilling on communications different communication approaches are suitable for different types of people so we use segmentation to provide you with the most appropriate communications for you;
• Sending marketing and offers different marketing approaches may be used with certain segments where we think our marketing will perform more effectively;
• Tailoring or managing products we may tailor your accounts, products or services based on a segment that you are grouped into (e.g. changing product terms such as APR).
• Deciding whether we need to help you certain details in your information may suggest that you are likely to become financially vulnerable and we may need to help you. For example, if we have information that shows you have moved from paying the full amount of your credit card to paying off only the minimum amount each month, this could be one sign that you may be having some financial difficulties and that we may be required to help you;
• To take action in relation to your account we may take action on your account such as restricting the use of your account or closing it due to inactivity.

This approach helps us to manage our accounts, products, services and marketing more effectively and meet industry and regulatory requirements (e.g. around customer indebtedness). This profiling and automated decision making may lead to changes on your account, product or service or in the way that we interact with you (communications or marketing).

Your rights in relation to automated decision making

You have rights in relation to certain automated decision making which means that before the end of the period of one month beginning with receipt of the automated decision you can request us to:

1. reconsider the decision; or
2. take a new decision that is not based solely on automated decision making and ask that a person review it.

If these rights apply you will be notified. If you want to know more about these rights, please contact us.