Privacy Policy

We collect personal data about you in the following ways:

• directly from you when you fill in forms on our site, manage your loan online or correspond with us by email, phone or otherwise;
• by observing how you access and use our products and services. For example, how you use our website or how you manage your accounts with Lendable. This includes recording how and when you submit your loan application and other information to us;
• from organisations that have your consent to share your data with us or for a separate legal basis for a specific or defined purpose. This could include for direct marketing or assessing your eligibility for a partner's product which may be suitable for you;
• from public sources, for instance the Companies House register, the Individual Insolvency Register, the 'Open Register' part of the electoral register. This may include tracing you if you have moved in order to recover monies owed to us; and
• from third party organisations such as Credit Reference Agencies, Fraud Prevention Agencies and Account Information Service Providers. The Credit Reference Agencies provide information on your financial behaviour. This is referred to as your credit history and gives lenders information on how you manage your finances (including things like your mortgage, credit cards overdrafts, loans, mobile phone contracts, and utilities).

We may hold and use various types of personal information collected at the start of, and during your relationship with us. We will limit the collection and processing of these personal data to what is necessary to achieve the purposes identified in this notice.

The information you provide to us must be correct, accurate, complete and not misleading.

Personal information may include:

• personal details including your name, address, previous address, phone numbers, email address, date of birth, employment status and home ownership details;
• financial and banking information including account details and transactional information;
• open banking data that you have authorised us to access;
• demographic and lifestyle information;
• information collected from Credit References Agencies, Fraud Prevention Agencies and Account Information Service Providers. We will collect this information at the point you first enquire about your loan and on a continuing basis as we manage your loan;
• details of the loan(s) you hold and have held with us;
• details of any contacts that we have had with you;
• details of how you applied for your loan (for example which browser you applied with);
• details of any contact with us including any telephone, email or other communication with you; and
• information collected through customer feedback surveys;

In some circumstances we may also collect and process special categories of personal information. This is to help ensure that our services are accessible and so that we can offer appropriate levels of support where required.

We may use your information:

• to process and complete your application for a loan;
• to search Credit Reference Agencies' and Fraud Prevention Agencies' records;
• to make an initial lending decision and to assess your eligibility for additional borrowing;
• to set up and process payments and prevent fraudulent transactions;
• to communicate effectively with you when applying for, agreeing to and undertaking the loan agreement, to effectively answer and manage any questions, concerns or complaints you may have;
• to update our records and maintain your account with us;
• to offer you products and/or services that may be of interest to you, where you have consented to be contacted for such purposes. This may include us making periodic searches at Credit Reference Agencies;
• to monitor, review and improve the content and appearance of our website, to ensure it is presented in the most effective manner for you;
• to maintain and develop our business systems, including without limitation, testing and upgrading them;
• to trace your whereabouts if we cannot contact you;
• to recover any money you owe us;
• to comply with our legal and regulatory obligations;
• for any other specific purpose which we notify you of at the time your personal information is collected;
• to pre-populate fields on our site to make it easier for you to navigate when you return to our website and login as an existing customer; and
• to help us analyse our business and develop marketing strategies, develop products and improve our advertising materials.

We may monitor and record calls, emails, SMS and other communications to ensure transactions are executed correctly, detecting any vulnerabilities you may have, and for security, quality control, training and fraud prevention purposes.

If we cannot offer you a product, we may check your eligibility for loans and/or other relevant credit products from our panel of trusted lenders and brokers. We will always seek your consent to do this and in assessing eligibility our partners will always use soft checks which will not impact your credit file. Our partners include:

• Monevo Group https://www.monevo.co.uk/terms-of-service, https://www.monevo.co.uk/privacy-policy
• Bamboo Loans https://www.bambooloans.com/s/how-we-use-your-information/
• Oakbrook Finance Ltd trading as Likely Loans https://likelyloans.com/terms-of-use, https://likelyloans.com/privacy-policy
• Aro Finance Limited https://aro.co.uk/terms-and-conditions/, https://aro.co.uk/privacy-policy/

We collect and use your personal information where it is necessary for us to carry out our lawful business activities. Our grounds for processing your data are as follows:

Contractual necessity

We may process your information where it is necessary to enter into a contract with you or to perform our obligations under that contract. This may include processing to:

• assess your eligibility for the products and services we provide,
• sharing information to assess your creditworthiness with Credit Reference Agencies, Fraud Prevention Agencies and Account Information Service Providers;
• to assess your eligibility for similar products including new loans. This may include making periodic searches at Credit Reference Agencies;
• provide and administer the products we offer, including:
  • setting up your account;
  • verifying your contact information;
  • collecting and providing to you required information and documents including statements and formal notices;
  • disbursing money and processing payments;
  • to manage fees, charges and interest due on your account;
  • to send you service communications and notices required by law;
  • to collect and recover outstanding sums owed to us; and
  • to address any enquiries or complaints we receive from you or a representative you have appointed.

Legal obligation

We may process your data where it is a legal or statutory obligation on us. This may include processing to:

• confirm your identity;
• detect, investigate and report transactions in order to comply with laws relating to money laundering, financial crime and international sanctions;
• assess affordability of any credit products for which you apply;
• detecting, investigating and reporting financial crime, and taking measures to prevent this;
• maintain records of our business as required by law;
• complying with laws which require us to provide information, directly or indirectly to any national authority, for the purpose of the calculation and collection of tax;
• responding to enquiries and requests for information by any of our Regulators including the Financial Conduct Authority and Information Commissioner's Office;
• creating and submitting reports required by any of our Regulators;
• to otherwise meet our obligations under all laws and regulations and codes of practice which apply to our business activities; and
• where we have a duty to protect vulnerable customers and provide them with support.

Legitimate interest

We may process your information when we have a business or commercial reason to do so. If we do, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is. This may include processing to:

• develop new products and services and identifying which may be of interest to you;
• contacting you to make you aware of such products and services, where we have the relevant permission to do so. This may include a reasonable period after your relationship has ceased with us;
• statistical analysis, analytics and profiling, for example, to create scorecards, models and variables in connection with the assessment of credit, fraud, vulnerabilities, risk or to verify identities, to monitor and predict market trends, and for analysis such as loss forecasting;
• monitor, review and improve the content and appearance of our website, to ensure that content from our website is presented in the most effective manner for you assess how our customers use our website, products and services;
• maintain and develop our business systems, including without limitation, testing and upgrading them;
• sharing information with organisations who introduce you to us under a commercial agreement;
• to recover monies owed;
• to sell debts to other firms;
• to share your information with third parties for the purpose of preventing fraud and financial crime; and
• to obtain finance for the products we provide.

We may use third party companies to provide services on our behalf. This may require these organisations to access and process your personal data. These may include:

• Credit Reference Agencies;
• Fraud Prevention Agencies including CIFAS;
• Account Information Service Providers;
• communications service providers offering mail, email and SMS text services;
• Debt Collection Agencies, Debt Management Companies and companies specialising in customer reconnection, asset repossession and general information gathering visits;
• debt purchasers;
• customer survey providers in order to receive feedback and improve our services;
• IT service providers;
• data security providers for debugging and product improvement purposes;
• legal service providers;
• digital and direct marketing service providers;
• third party quality assurance providers
• payment processors;
• trusted lenders and brokers who will assess your eligibility for products; and
• A prospective assignees of your account; and
• We use GoCardless to process your Direct Debit payments. More information on how GoCardless processes your personal data and your data protection rights, including your right to object, is available at https://gocardless.com/legal/privacy/;
• We use Evolution Funding Ltd who contact our auto loan customers where they have chosen vehicles outside of a dealership in order to run vehicle and seller checks. More information on how Evolution Funding Ltd processes your personal data is available at https://www.evolutionfunding.com/public/privacy-notice/.

To deliver services to you, we, or one of our service providers, may transfer your personal data to countries outside either the UK or the European Economic Area (EEA), whose personal data protection laws are less strict than in the UK or the EEA. Where we or one of our service providers do so, we will make sure suitable safeguards are in place to protect your personal data, in line with data protection law. The safeguards we use will depend on the circumstances and the third party who we transfer data to, but include the EU Commission's standard contractual clauses. Please contact asda@lendable.co.uk if you want to know more details about the above safeguards or obtain a copy of the standard contractual clauses we use to transfer data outside the UK and the EEA.

To process your application, we will perform credit and identity checks on you with one or more credit reference agencies ("CRAs"). Where you take services from us we may also make periodic searches at CRAs to manage your account with us. To do this, we will supply your personal information to 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. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.

We will use this information to:

• assess your creditworthiness and whether you can afford to take the product;
• verify the accuracy of the data you have provided to us;
• prevent criminal activity, fraud and money laundering;
• manage your account(s);
• trace and recover debts; and
• ensure any offers provided to you are appropriate to your circumstances.

We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your accounts including settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt and payment performance. This information may be supplied to other organisations by CRAs.

When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.

Where you have a financial association with someone your records may be linked, so you should discuss your application with them before you make it. 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 file for a disassociation with the CRAs to break that link.

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 at https://www.transunion.co.uk/crain. Credit Reference Agency Information Notices (CRAIN) are also accessible from each of the three CRAs – clicking on any of these three links will also take you to the same CRAIN document:

• TransUnion: https://www.transunion.co.uk/crain
• Experian: https://www.experian.co.uk/crain
• Equifax: https://www.equifax.co.uk/crain

The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance or employment. The Fair Processing Notices for Cifas provides further details on how your information will be used by us and these fraud prevention agencies, and your data protection rights.

We use a tool provided by TrueLayer Limited (www.truelayer.com) ("TrueLayer") that allows you to send information on your payment accounts to us and other service providers.

In order to use this service, you will be asked to agree to their Terms of Service and enter your payment account details with TrueLayer or, for Open Banking connections, you will be redirected to your bank by TrueLayer in order to authenticate yourself. The Terms of Service set out the terms on which you agree to TrueLayer accessing information on your payment accounts for the purposes of transmitting that information to us.

TrueLayer is subject to UK and EU data protection laws and is required to treat your data in accordance with those laws, as well as the Terms of Service and TrueLayer's Privacy Policy.

TrueLayer is authorised by the UK Financial Conduct Authority under the Payment Services Regulations 2017 to provide account information services and payment initiation services (Firm Reference Number: 901096).

We may also obtain Open Banking data from other third parties which may include details of your transactions with other financial institutions.

CONSEQUENCES OF PROCESSING

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services or financing you have requested, or we may stop providing existing services to you.

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 financing to you. If you have any questions about this, or believe that your information has been processed inaccurately, please contact us at the address above.

DATA TRANSFERS

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.

When we first collect your data, we will give you the opportunity to confirm your preferences. Any electronic marketing communications we send you will include clear instructions to follow should you wish to unsubscribe at any time. You may also amend your contact preferences in the following ways:

• by logging into your online account and amending details there;
• by emailing us at asda@lendable.co.uk; or
• by calling us on 0808 178 1505.

As a data subject, you have a number of rights:

• the right to access the personal data we hold about you;
• the right to rectify inaccurate personal data or complete it if it is incomplete;
• the right to have your personal data deleted;
• the right to request restriction of or suppression of your personal data;
• the right to obtain and make use of your personal data for your own purposes across different services ("portability");
• the right to object to the processing of your personal data in certain circumstances;
• rights related to automated decision-making including profiling, and
• the right to withdraw consent at any time. In certain circumstances, we may need to get your consent before we can access or process your personal data. If this happens, we will always ask for your consent first. If you have given us consent in the past but subsequently change your mind, you can withdraw your consent at any time.

Your data protection rights are subject to certain restrictions and conditions and financial organisations are required to retain a range of your information for legal and regulatory reasons including responsible lending and the prevention of financial crime. Lendable is required to keep a record of the information reported to the Credit Reference Agencies about you and will therefore retain repayment information regarding your loan for six years from the date that the loan is settled/closed. If your account is recorded as defaulted, the data is kept for six years from the date of the default. This may be extended where we require this to bring or defend legal claims.

If you think that any of the personal data we hold about you is wrong or incomplete you have the right to challenge it.

We will not make a charge for handing your rights request, unless we consider it to be manifestly unfounded or excessive involving a disproportionate effort (particularly if this is repeated request). If you would like to exercise any of the rights outlined above, you can make a request verbally by calling 0808 178 1505 or in writing by emailing asda@lendable.co.uk.

We will assess your request and if we decided not to act upon it or place certain restrictions on it, we will inform you of our reasons for this.

You have the right to complain to us and to the data protection regulator, the Information Commissioner's Office. Their address is: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. They can be contacted by phone on 0303 123 1113 (local rate) or 01625 545745 if you prefer to use a national rate number.

You can find details on how to report a concern at: https://ico.org.uk/make-a-complaint/

We will not typically ask you for any 'special categories' of personal data. This is also referred to as 'sensitive personal data' and includes information revealing an individual's political opinions, racial or ethnic origin, religious or philosophical beliefs, or trade union membership, and genetic data, biometric data, data concerning health or data concerning an individual's sex life or sexual orientation.

We may process personal data about your health or medical conditions, where we need to understand this to provide you with support, or to make adjustments in how we provide you with information or provide you with additional services that you may need. Companies acting on our behalf specialising in identifying vulnerable customers or customer reconnection and information gathering visits may also process personal data about your health or medical conditions for this purpose. If we process such data, we will do so to comply with our legal obligations to support you if you are, or become a vulnerable customer, and to establish, take or defend any legal action.

We will retain your personal data for as long as we are required to under relevant legislation and regulation, and where no specific rules apply, for no longer than it is necessary for our lawful purposes. This will usually be no more than six years from the end of our relationship with you. The retention period of your personal data may need to be extended where we require this to bring or defend legal claims.

We may also retain data for longer periods for statistical purposes, and if so we will anonymise this.

We use leading cloud services that have adopted industry security best practice frameworks to protect your data in transit and at rest.

We may use your personal data in automated processes to make decisions about you. You have the right not to be subject to a decision based solely on automated processing, if this will have a legal or other significant effect on you (certain exceptions apply).

We use automated decision making in:

• credit scoring and affordability assessment. We use data collected from yourself through online forms, your use of our site and Credit Reference Agencies and other third parties to assess your creditworthiness and affordability of the product applied for. If you do not agree with the decision you have the right to appeal the outcome of these automated decisions and ask for them to be reconsidered manually. Lendable may require additional relevant information to be provided by you before human oversight of a specific decision will take place;
• fraud and money laundering risk identification. If our processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct, or is inconsistent with information that you have provided previously, or you appear to have deliberately hidden your true identity we may decide that you pose a fraud and money laundering risk;
• profiling to identify whether you are suitable for products and services we offer and to inform you of these. This profiling will be conducted by us when assessing suitability of existing customers for new loans. We will use profiling in conjunction with our partners when developing new prospect marketing campaigns; and
• determining appropriate action to take, where your account has gone into arrears or default. You have the right to ask for this to be reconsidered manually.

Our website may contain hyperlinks to websites that are not operated by us. We urge you to review any privacy policy posted on any site you visit before using the site or providing any personal information about yourself.

We may use cookie technology on our website to collect some of the information detailed in this policy.

Cookies are small text files stored on your device or internet browser when you visit us. We use cookies mainly to improve the performance of the Lendable website and our service for our customers. Our Cookie Policy explains in more detail what types of cookie we use, why we use them and how to identify and disable them.