Guarantor My Loan Privacy Policy

Protecting your personal details on our website.

Last updated: 17th January 2017

Match the Cash Limited trading as guarantormyloan.co.uk and guarantorloan.co.uk (“we”, “us” or “our”) is committed to protecting and respecting your privacy.

 For the purpose of the Data Protection Act 1998, the data controller is Match the Cash Limited of Acre House, 11/15 William Road, London, NW1 3ER. We are registered under the Data Protection Act 1998 under number ZA055459.

We provide a platform (the “Platform”) via the Website for lending and borrowing transactions conducted between our customers. This policy sets out the basis on which any information we collect from you, or that you provide to us, will be processed by us, and how we use it in the operation of the Platform. By visiting www.guarantormyloan.co.uk (the “Website”) you are accepting and consenting to the practices described in this policy. You should read this policy in conjunction with the Website terms and conditions.

1.    General

1.1    Certain parts of this policy only apply to borrowers and guarantors of such borrowers, and other parts only to lenders. Where this is the case, we will make it clear in the opening paragraph of the relevant section.

1.2    As well as private individuals, lenders may be limited liability companies, limited liability partnerships, unlimited partnerships, sole traders or unincorporated associations. In these circumstances, this policy will apply to, and 'you' and 'your' refer to, the individuals who are you as the lender if a sole trader, or you as a director, partner, member, guarantor or employee of the lender. 

1.3    We may also seek and obtain personal information about other parties linked financially with you (for example, the guarantor of the borrower). You should therefore ensure they read this policy and you have their consent to disclose the information about them.

2.    Collecting information

2.1.    We may collect and process the following information about you:

2.1.1.    Information you give us. You may give us information about you:

2.1.1.1.    when you contact us with an enquiry or in response to a communication from us, in which case, this may tell us something about how you use our services; and

2.1.1.2.    when you agree to take a service or product from us, in which case this may include:

2.1.1.2.1.    contact details, including your name, address, postcode, and other contract information such as your telephone number;

2.1.1.2.2.    date of birth;

2.1.1.2.3.    documentation verifying your identity, including copies of your passport, utility bills, and bank statements;

2.1.1.2.4.    information provided in your application form, including in relation to your financial requirements; 

2.1.1.2.5.    how you will pay for the product or service; and

2.1.1.2.6.    bank details and credit and debit card details.

2.1.2.    Information we collect about you. We may collect information about you:

2.1.2.1.    from documents that are available to the public, such as the electoral register; and

2.1.2.2.    with regard to each of your visits to the Website, including:

2.1.2.2.1.    technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and

2.1.2.2.2.    information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from this Website (including date and time), page response times, download errors, and length of visits to certain pages.

3.    Using your personal information

3.1.    Your information is an important part of our business and we may use such information for the following purposes and shall not keep such information longer than is necessary to fulfil these purposes:

3.1.1.    To help us to identify you when you contact us.

3.1.2.    To help us to identify accounts, services and/or products which you could have from us or selected partners from time to time. We may do this by automatic means using a scoring system, which uses the information you have provided and/or any information we hold about you and from third party agencies (including credit reference agencies).

3.1.3.    To help us to administer and to contact you about improved administration of any accounts, services and products we have provided before, do provide now or will or may provide in the future.

3.1.4.    To allow us to carry out marketing analysis and customer profiling (including with transactional information), conduct research, including creating statistical and testing information.

3.1.5.    To help to prevent and detect fraud or loss.

3.1.6.    To allow us to contact you in any way (including mail, email, telephone, visit, text or multimedia messages) about products and services offered by us and selected partners unless you have previously asked us not to do so.

3.1.7.    We may monitor and record communications with you (including phone conversations and emails) for quality assurance and compliance.

3.1.8.    We may check your details with fraud prevention agencies. If you provide false or inaccurate information and we suspect fraud, we will record this.

3.1.9.    In respect of borrowers and guarantors of such borrowers:

3.1.9.1.    we may check details on applications for credit and credit related and other facilities; and

3.1.9.2.    if you do not repay money which the borrower has borrowed, we may trace your whereabouts and recover debts or enforce a loan agreement.

3.1.10.    In respect of lenders, we may check details on applications for lending and other related facilities.

3.1.11.    For any other specific purposes in relation to your activities via the Platform. 
3.2.    We will not disclose your information to any third party except in accordance with this policy.

3.3.    We may allow other people and organisations to use the information we hold about you in the following circumstances:

3.3.1.    If we, or substantially all of our assets, are acquired or are in the process of being acquired by a third party, in which case information held by us about our customers will be one of the transferred assets.

3.3.2.    If we have been legitimately asked to provide information for legal or regulatory purposes or as part of legal proceedings or prospective legal proceedings.

3.3.3.    We employ companies and individuals to perform functions on our behalf and we may disclose your information to these parties for the purposes set out in clause 3.1 or, for example, to verify your identity, to carry out credit checks on you, for delivering packages, sending postal mail and email, removing repetitive information from customer lists, analysing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit and debit card payments and providing customer service.

Those parties are bound by strict contractual provisions with us and only have access to the information needed to perform their functions, and may not use it for other purposes. Further, they must process such information in accordance with this policy and as permitted by the Data Protection Act 1998. From time to time, these other people and organisations to whom we may pass your personal information may be outside the European Economic Area. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this policy and the Data Protection Act 1998.

3.4.    Where you give us information on behalf of someone else, you confirm that you have provided them with the information set out in this policy and that they have not objected to such use of their information.

4.    Borrowers and guarantors

4.1.    In addition, we may disclose the personal information of a borrower or a guarantor of such borrower to:

4.1.1.    debt collection agencies, security trustees, and other legal representatives if required to enforce the terms of any loan agreement or guarantee and indemnity agreement; and

4.1.2.    a discretion provision fund which may be set up for the purposes of compensating us and the relevant lenders where you have failed to meet your repayment obligations under any loan agreement.

4.2.    In connection with any transaction which we enter into with you:

4.2.1.    We, and other companies in our group, may carry out credit and fraud prevention checks with one or more licensed credit reference and fraud prevention agencies such as Call Credit Information Group Limited, Equifax Limited, Experian Limited and Perfect Data Solutions Limited. Credit agencies supply the following information to us:

4.2.1.1.    information about you, such as previous applications for credit and similar personal credit information in your name or in relation to your financial associates and business partners;

4.2.1.2.    public information such as County Court Judgments and bankruptcies; 

4.2.1.3.    electoral register information on you and your business partners; and

4.2.1.4.    fraud prevention information. 

Information held about you by these agencies may be linked to records relating to other people living at the same address with whom you are financially linked. These records will also be taken into account in credit and fraud prevention checks. 
The credit reference agencies will add details of  our searches and your application to the record which they hold about you. The credit reference agencies will also add details of your loan agreement with us, the payments you make under it and any default or failure to keep to its terms. Your credit reference agency records will be seen  by other organisations that make searches with those agencies to help make credit and insurance decisions about you and members of your household with whom you are financially linked and for debt collection and fraud prevention. This includes those who have moved house and who have missed payments. Credit reference agencies will keep records of outstanding debt on file for six years after they are closed, whether settled by you or defaulted. While you are a customer of ours, we may carry out extra credit searches so we can manage your account.

4.2.2.    If you provide false or inaccurate information to us and we suspect fraud, we will record this and may share it with other people and organisations such as fraud prevention agencies. We, and other credit and insurance organisations, may also use technology to detect and prevent fraud. We and other organisations may access and use this information to prevent fraud and money laundering, for example, when:

4.2.2.1.    checking details on applications for credit and credit related or other facilities;

4.2.2.2.    managing credit and credit related accounts or facilities; and

4.2.2.3.    recovering debt.

4.2.3.    If you need details of those credit agencies and fraud prevention agencies from which we obtain and with which we record information about you, please write to our Data Protection Manager at Match the Cash trading as guarantormyloan.co.uk Acre House, 11-15 William Road, London, NW1 3ER. 

5. Borrowers – Viewing access to your bank account transaction information

5.1 You are not required to provide us with viewing access to your bank account transaction information (Transaction History) or internet banking access details. You may still be allowed to apply for a loan with us if you do not provide us with this information. However, if you do it will help us make an informed decision about whether we can lend to you.

If you agree that we may access your Transaction History the following provisions shall apply.

5.2 Provide Accurate Information. You, agree to provide true, accurate, current and complete information about yourself and your bank accounts (with us or third parties) and you agree to not misrepresent your identity or your account information. You agree to keep your bank account information up-to-date, accurate and complete.

5.3 Purposes. We will access your Transaction History using the services of a credit reference agency called Perfect Data Solutions Limited (PDS). We will use your Transaction History to assess your creditworthiness and whether the loan you seek is affordable.

Neither we nor PDS will store or have access to your internet banking credentials, PIN codes or passwords. That information is encrypted in transit and stored by a third party service provider upon their servers in a secure environment outside the EEA.

5.4 Third Party Accounts. By agreeing to allow us viewing access to your Transaction History, you authorise PDS and PDS's service providers to access third party sites designated by you, on your behalf, to retrieve information requested by us, and to register to view bank statements over a period of up to 90 days. You agree that PDS and PDS's service providers may, and are instructed by you as your agent and nominated representative, with full power of substitution and re-substitution, for you and in your name, place and stead, in any and all capacities, to access third party internet sites, servers or documents, retrieve information, and use your

information, all as described above, with the full power and authority to do and perform each and every act and thing requisite and necessary to be done in connection with such activities, as fully to all intents and purposes as you might or could do in person. This will include the following purposes: copying Transaction History over a 90 day period and storing the copied Transaction History on our servers.

You agree that the Transaction History shall also be used by PDS for credit reference agency purposes and may be taken into account when producing your individual credit score which may be shared with other organisations as part of your credit record.

You acknowledge and agree that when we, PDS or PDS's service providers access and retrieve information and Transaction History from third party sites, this is undertaken as your agent, and not the agent on behalf of any third party (including the bank account provider). You should be aware that third party account providers shall be entitled to rely on this authorisation and agency granted by you. You should also be aware that this service is not endorsed or sponsored by any third party bank account providers. We would recommend that you refer to the terms and conditions of your internet banking provider if you would like more information.

You understand that allowing us to review your Transaction History is at your sole risk. We are only able to review your Transaction History on an "as is" and "as available basis" as it is made available to us by service providers. It may not be available to us from time to time.

We cannot guarantee that allowing us to review your Transaction History will guarantee the success of your loan application or the rate at which the loan is available.

6.    Automated decisions – your rights

6.1.    We may use a credit-scoring system, i.e. an automated system to assess any aspect of your credit worthiness and decide whether to admit you to the Platform. You may ask us to ensure that, when we are evaluating your application for finance or to become a lender, we don’t base any decisions solely on an automated process. You must notify us of this request in writing.

6.2.    If you make such a request, you will then have the right to be notified where such a decision is or will be based on an automated process. If we notify you that we have taken such a decision, you may request us to review that decision other than by automatic means by writing to us within 21 days of receiving the notification. 

7.    Security measures

7.1.    We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures mean that we may request proof of identity before we disclose personal information to you.

7.2.    It is important for you to protect against unauthorised access to your password (where applicable) and to your computer. Be sure to sign off when you finish using a shared computer.

7.3.    Our employees will collect your debit card numbers when processing your loan. We retain only the last four digits of your debit card numbers on the Platform. 

7.4.    If we contact you, or you contact us by telephone, we will verify your identity by asking you certain questions in relation to yourself and the information which you have previously provided to us. 

7.5.    We may record telephone calls for security and training purposes. 

8.    The internet

8.1.    If you communicate with us using the internet, we may occasionally email you about our services and products. When you first give us information through the Website, we will normally give you the opportunity to say whether you would prefer us not to contact you by email. You can also always send us an email (at the address set out below) at any time if you change your mind. 

8.2.    Please remember that communications over the internet, such as emails and webmails (messages sent through a website), are not secure unless they have been encrypted. Your communications may go through a number of countries before they are delivered - this is the nature of the internet. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to the Website: any transmission is at your own risk.

9.    Cookies 

9.1.    When we provide services, we want to make them easy, useful and reliable. In order to improve the Website we may place small amounts of information on your computer. These are called 'cookies'. A cookie is a small amount of data which often includes a unique identifier that is sent to your computer, tablet or mobile phone (referred to in this policy as a ‘device’) from the Website and is stored on your device’s hard drive.

9.2.    A cookie records on your device information relating to your internet activity (such as whether you have visited the Website before). The cookies we use on the Website won't collect personally identifiable information about you and we won't disclose information stored in cookies that we place on your device to third parties.

9.3.    If you don't want us to use cookies when you use the Website, you can adjust your internet browser settings not to accept cookies. Your web browser's help function should tell you how to do this. Alternatively, to find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit the website: http://www.allaboutcookies.org. This website will also explain how you can delete cookies which are already stored on your device. In addition, visit www.google.co.uk/goodtoknow/data-on-the-web/cookies for a video about cookies. 

9.4.    The cookies used on the Website have been categorised based on the categories found in the ICC UK Cookie guide, as follows:

Category 1: Strictly necessary cookies

These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for, like shopping baskets or e-billing, cannot be provided.

Category 2: Performance cookies

These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.

Category 3: Functionality cookies 

These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as a live chat session. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

Category 4: Targeting cookies or advertising cookies 

These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation. 

9.5.    The list below shows the cookies that we use on the Website, other than those that are strictly necessary to this service. 

9.6.    We use Remarketing with Google Analytics to advertise online and display content specific advertisements to you when you visit websites that have the Google Display Network implemented. Both us and third parties (including Google Inc.) use remarketing cookies – both first party (such as Google Analytics) and third party (such as DoubleClick) – to serve more relevant ads based on your past visits to the Website, whether you are on the Website or on other websites.

9.7.    You may opt-out of Google’s use of cookies by visiting Google’s Ad settings at http://www.google.com/settings/ads or opt-out of third-party vendor’s use of cookies by visiting http://www.networkadvertising.org/choices/.

9.8.    If you have any queries about these, or would like more information, please contact our Data Protection Manager. 

10.    Links

10.1.    The Website may include third-party advertising and links to other websites. We do not provide any personally identifiable customer information to these advertisers or third-party websites.

10.2.    These third-party websites and advertisers, or internet advertising companies working on their behalf, sometimes use technology to send (or 'serve') the advertisements that appear on the Website directly to your browser. They automatically receive your IP address when this happens. They may also use cookies, JavaScript, web beacons (also known as action tags or single-pixel gifs), and other technologies to measure the effectiveness of their ads and to personalise advertising content. 

10.3.    We do not have access to or control over cookies or other features that they may use, and the information practices of these advertisers and third-party websites are not covered by this policy. 

10.4.    Please note that these websites have their own privacy policies and website terms and conditions. We do not accept any responsibility or liability for these policies. Please check their privacy policies and their website terms and conditions when you visit them and before you submit any personal information to these websites. 

10.5.    The Network Advertising Initiative offers useful information about internet advertising companies (also called 'ad networks' or 'network advertisers'), including information about how to opt-out of their information collection.

11.    Marketing 

11.1.    When we first obtain information from you, or when you take a new service or product from us, we will give you the opportunity to tell us if you do or do not want to receive information from us about other services or products (as applicable). You can normally do this by ticking a box on an application form or contract. You may change your mind at any time by emailing us. 

12.    Access to information 

12.1.    The Data Protection Act 1998 gives you the right to access information held about you. If you would like access the information that we hold about you, you can do this by emailing us or writing to us at the address noted above. Any access request may be subject to a fee of £10 to cover administrative costs.

12.2.    We aim to keep the information we hold about you accurate and up to date. If you tell us that we are holding any inaccurate information about you, we will delete it or correct it promptly. Please email us or write to us at the address above to update your information.

13.    Further Information

13.1.    We may amend this policy from time to time without notice to you, in which case, we will publish the amended version on the Website. You confirm that we shall not be liable to you or any third party for any change to this policy from time to time. It is your responsibility to check regularly to determine whether this policy has changed.

13.2.    You can ask us for a copy of this policy and of any amended policy by writing to the above address or by emailing us.

 
13.3.    If you have any questions about any aspect of this policy or do not agree with it, please write to us at Data Protection Manager, Acre House, 11/15 William Road, London, NW1 3ER or email us at customerservice@guarantormyloan.co.uk.

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