Terms of service

We will use your personal data to appropriately respond to your general queries or complaints as is necessary to manage your contract. Phone calls will be recorded for quality assurance and training purposes, as our legitimate business interest.

We will process your personal data to improve our processes, through analysis of communications such as call recording and improve the products and services we offer, including the use of surveys, as a legitimate business interest.

Credit agencies
We will process data about you when you sign up for our products and services to carry out credit checks using your data and data available on Companies House and public sources as our legitimate business interest to mitigate any risk.

We may also carry out further credit checks on ‘high usage’ and ‘high risk’ customers during the course of the contract using a Credit Reference Agency, as our legitimate interest to mitigate on-going risk, to assess credit worthiness and for fraud prevention. This means that your credit records will be searched, along with those of anyone who is financially associated with you such as your spouse or partner. The Credit Reference Agency will keep a record of this search and place a “footprint” on your credit file and collect and maintain information about consumers’ and businesses’ credit behaviour. This includes data sourced from the Electoral Register, fraud prevention, and credit information – including details of previous applications and the conduct of your accounts – and public information such as County Court Judgements, decrees, and bankruptcies.

The Credit Reference Agency, which operates as an independent data controller and whose own privacy notices apply, that we use is Experian.

Compliance with legal and regulatory requirements
We will process data where we are under a legal or regulatory requirement to do so, including sharing of data with third parties. This can include regulators (Information Commissioner Officer, and Financial Conduct Authority), courts or law enforcement agencies.

How long we store your personal data for
Our policy is to only retain your personal data for as long as necessary. The retention period will vary depending on the purpose of processing, the products and services, the type of personal data, your relationship with us and any legal or regulatory requirement we may have.

Your rights and how to exercise them
The data protection legislation provides you with rights over the personal data we collect and process about you. These include:

Your right to be informed – you have the right to be informed how your data is being processed, which is largely provided by this Privacy Notice.
Your right to access – you have the right to request that we provide you with a copy of your personal data which we hold about you.
Your right to rectification – you have the right to request that we update your personal data if it is inaccurate or incomplete.
Your right to erasure – you have the right to request that we delete your personal data which we are holding, commonly known as the Right to be Forgotten.
Your right to restrict processing – you have the right to request that we restrict the way we process your personal data.
Right to data portability – you have the right to request that we provide your personal data to you or a third party in a structured, commonly used and machine-readable format.
Right to object to processing – you have the right to request to object to us processing personal data.
The extent of these rights are limited by law and we may not act on some parts or all of your request(s) where the rights are not applicable. If we choose to not act on the request(s), we will provide you with an explanation. In order to submit a request or for further information, you may contact us using the details provided above.

If you are dissatisfied with our processing of your data, you have the right to raise a complaint with our business Customer Service team, our Compliance Team, or the Information Commissioner Office (www.ico.org.uk). If you do have a complaint, we ask that you contact our Compliance team in the first instance using the details provided above.

Other formats
We are able to provide this Notice in large print, coloured paper, in Braille or audio upon request. To make such a request please contact us using the details provided above.

Other matters
This Privacy Policy was designed to be concise, transparent, intelligible, easily accessible and easy to read. If you have any questions, please contact us using the details provided above. We primarily process data within the UK. Where processing needs to occur outside the UK, due to system constraints, that will be subject to contractual agreement and contractual safeguards.

This Privacy Notice may be amended from time to time, as is our right. Any such change will be made available in this Notice to keep you informed about how we process your personal data. For any significant change made to the Privacy Notice, you relevant data subjects will be contacted directly via email or letter where feasible.

If you follow an internet link from our website to a partners’ website or engage with other independent data controllers, their privacy notices will apply. We do not accept any responsibility or liability for those notices. Please check those notices before you submit any personal data to their websites.