Privacy Policy

PRIVACY POLICY

Loan Logics Limited (‘we’ or ‘us’ or ‘our’) of Top Floor, Waterside Court, Falmouth Road, Penryn, Cornwall TR10 8AW are committed to protecting and respecting your privacy. This privacy notice explains how we use the information we collect from you or that you provide to us.

We are registered with the Information Commissioner’s Office. Our ICO registration number is ZA103878. Details can be found on the Public Register at www.ico.org.uk. Loan Logics Limited is a company registered in England and Wales under company number 08723302 and our registered office is at 19th Floor, 1 Westfield Avenue, London E20 1HZ.

HOW TO CONTACT US:

Should you have any queries about this policy or wish to exercise any of your rights, you can contact us at info@loanlogics.co.uk or by post Loan Logics Limited, Top Floor, Waterside Court, Falmouth Road, Penryn, Cornwall, TR10 8AW or by telephone on 01326 375505.

THE TYPE OF PERSONAL INFORMATION WE COLLECT

We process your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never intentionally collect any unnecessary personal data from you and do not process your information in any way other than specified in this policy.

The information we collect will depend on your engagement with our company and may include:

• Personal details, for example, names, gender, date of birth and place of birth.
• Contact details, for example, your residential address, email address, and telephone number(s).
• Information about your identity for example, your signature, photo ID, passport information, National Insurance number, National ID card and nationality.
• Your financial information and information about your relationship with us. This includes the product(s) you hold, the purpose of your loan, how you deal with us, your payment history, credit risk rating, transactions records, and information about complaints and disputes. It will also include information about your employment and income, relevant court orders, tenancy agreements, and occupiers of your property.
• Investigations data, for example, the results and findings from customer due diligence checks, sanctions and anti-money laundering checks.
• Other information about you that you give us when you fill forms in or by communicating with us, whether face-to-face, by phone, email, online, or otherwise. This may include special category data such as health or medical information where you tell us this because you feel this will help us assist you better and if you provide documents that contain such information or otherwise volunteer such information to us.

We only retain your data for as long as is necessary and for the purposes specified in this policy.

If you make an application on behalf of another individual, jointly with another or on behalf of a business with others and you provide us with personal information related to them, then this privacy policy will also apply to the information that we collect about those individuals. You must provide a copy of this policy to them as soon as possible and confirm that they have read and understood it.

HOW WE COLLECT AND OBTAIN YOUR PERSONAL DATA

We collect your personal data directly, including:

• when you provide it to us during the course of our relationship, whether that be by telephone, in writing or by any other method of communication. 

Please be advised all telephone calls to and from our offices are recorded and retained. These recordings are kept for training, monitoring, and regulatory purposes.

We obtain your personal data indirectly when it is provided by third parties including:

• when you apply for a product through an intermediary.
• if another person provides your information to us when they apply to obtain a product from us.
• from fraud prevention agencies, credit reference agencies, tracing and debt recovery agents, government bodies and agencies, the electoral roll, and other sources of publicly available information when we conduct searches for the purposes of processing your application and/or during your relationship with us.

HOW WE USE YOUR PERSONAL INFORMATION

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing your information are:

• Where we have a legal obligation to do so.
• Where we have a legitimate interest.
• Where we do so with your consent.
• Where we do so for the performance of a contract we have with you, or because you have asked us to take steps before entering into a contract.

The table below sets out the main ways we process your information:

Type of processing:	Reason for processing:	Processing is necessary for:
Considering and processing your application	We need to process your personal data in order to decide whether we can offer you the product you have applied for and to evaluate any security and/or guarantee arrangements relating to a product.	A contract we have with you, or because you have asked us to take specific steps before entering into a contract. Our legitimate interests.
Performing credit searches and verifying your identity	We need to conduct credit searches and verify your identity before we can offer you a product or service. We need to do this to ensure that we are acting as a responsible lender, including with regards to fraud prevention and identity theft.	Our legal or regulatory obligations. Our legitimate interests.
Administering your account	We will use your information to administer your account in several ways, including: collecting loan repayments. providing you with account statements, notices. providing you with information such as changes to your interest rate. managing any arrears on your account. enforcing any security that we have in place. dealing with any queries or complaints that you may have. recovering debts due to us. keeping our records updated.	A contract we have with you, or because you have asked us to take specific steps before entering into a contract or our legal or regulatory obligations. Our legitimate interests. Our legal or regulatory obligations.
Responding to your requests to exercise your legal or regulatory rights	Where you have made a request relating to your legal or regulatory rights, such as those detailed in the “your information rights” section of this notice, we need to process your personal data in order to process and respond to your request.	Our legal or regulatory obligations.
Assisting third parties	To assist intermediaries or brokers who have provided a service to you, including: managing records about you. ensuring the type of business that third parties refer to us is appropriate. resolving any complaint made by you about a third party and/or any dispute between you and us regarding a third party.	Our legal or regulatory obligations. Our legitimate interests.
Making reasonable adjustments to our processes	We may record information relating to your health or personal circumstances where we need to make reasonable adjustments to our processes.	Our legal or regulatory obligations or where we have your explicit consent.

WHO YOUR PERSONAL DATA MAY BE SHARED WITH

So that we can provide you with products and services, meet our legal obligations and manage our business, it may be necessary to share your personal data with third parties including:

• Your mortgage advisor or intermediary who introduced you to us.
• Anyone acting on your behalf with authority to do so, such as insolvency practitioners, power of attorney or your professional advisors.
• Credit reference agencies (CRAs), fraud prevention agencies and law enforcement agencies.
• Debt collection agencies seeking to recover any debt owed to us. Agents or third-party contractors including data processors who we appoint to administer or operate your account, including any person who may replace us in the administration of your account.
• Our insurers.
• Legal and regulatory bodies, such as the Financial Conduct Authority (FCA), HMRC, the Information Commissioner’s Office (ICO), the UK Financial Services Compensation Scheme (FSCS), the Financial Ombudsman Service (FOS), our professional advisors and/or the courts.
• Organisations that provide us with business support services. For example, solicitors, compliance consultants, account service and administration companies, back-up and server hosting, IT software and maintenance platforms, document storage and management services, receivers, repossession agents, recoveries agents and property valuers.
• Any entity (and their professional advisors) who provide funding to us or any potential purchasers of our business or assets.

We take your privacy very seriously and other than in the ways specified in this notice we will never disclose or share data without your consent unless required to do so by law or reasonably necessary for a legitimate business purpose. We will not sell or share your data to third parties to use for marketing purposes.

CREDIT REFERENCE AGENCIES (CRAs)

To process your application, we will perform credit and identity checks on you with one or more CRAs. Where you have a mortgage with us, we may also make periodic searches at CRAs to manage your account with us. To do this, we will share your personal data with CRAs and they will give us information about you. This will include:

• Identity and contact data.
• Information from your credit application.
• Information about your financial situation and financial history.
• Public information (including the electoral register).
• Information about your shared credit; 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); and
• Trace and recover debts.

We will continue to share information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. 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 maybe seen by other lenders.

If you are making a joint application or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. CRAs will also link your records together and these links will remain on your and their files until you or your partner successfully files 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 data, data retention periods and your data protection rights with the CRAs are explained in more detail in the CRA information notice (CRAIN) which is accessible from each of the three CRAs. Any of the links below will take you to the same CRAIN document:

• TransUnion (formerly Callcredit)  www.callcredit.co.uk/crain
• Equifax  www.equifax.co.uk/crain.html
• Experian  www.experian.co.uk/crain/index.html

Please ask us if you require details of the CRAs or any other agencies from whom we obtain, and to whom we pass information about you. You have a right to receive this.

FRAUD PREVENTION AGENCIES

The personal information we collect 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.

Further details on how your information is used along with your rights can be found at https://www.cifas.org.uk/fpn

INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

We will only transfer your information outside the United Kingdom when the law permits us to do so. We usually do this in order to share your personal data with organisations who provide us business support services or our professional advisors.

Should we transfer your personal data to any other territories or countries outside the UK we ensure appropriate safeguards are in place, where required, to maintain the same levels of protection as are needed under data protection laws in the UK.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

Except as otherwise permitted or required by law or regulation, we will only retain your personal data for as long as necessary to fulfil the purposes we collected it for (as reasonably described in this privacy policy). This will be for a minimum of 6 years from the date our legal relationship with you has ended (for example, after a service has ended, or your account has closed and there are no outstanding matters to be addressed, such as a payment or complaint). If your application is declined, we will store your personal data in accordance with our record retention procedures and to comply with our legal obligations.

HOW WE KEEP YOUR PERSONAL INFORMATION SECURE

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.

KEEPING YOUR INFORMATION ACCURATE

We strive to ensure that your personal data is kept up to date and accurate. If any of the personal data you have given to us or third parties changes, such as your contact details or employment status, please promptly inform us in accordance with the terms and conditions of your agreement with us.

You will be required to provide us with any changes to your personal data under the agreement you enter into with us if your application for a product is accepted. If you fail to do so this will put you in breach of your agreement.

YOUR INFORMATION RIGHTS

You have a number of rights which are explained below, if you wish to exercise any of these rights you can do so by using the contact details at the start of this policy. If you make a request, we will provide this information within one calendar month of receipt of your request unless the request is complex or numerous in which case we may extend the period of compliance by up to two months and if this is necessary we will then notify you within one month of the date of receipt of your request:

Right to access: You have the right to access the personal data held about you and to obtain certain prescribed information about how we process it. This is commonly known as submitting a ‘data subject access request’.

Right to rectify your personal data: If you discover that the information we hold about you is inaccurate or incomplete, you have the right to have this information corrected.

Right to erasure: You may ask us to delete information we hold about you in certain circumstances; this is often referred to as the ‘right to be forgotten’. This right is not absolute and only applies in particular circumstances. It may not always be possible for us to delete the information we hold about you, for example, if we have an ongoing relationship with you or we are required to retain information to comply with our legal obligations or to exercise or defend legal claims.

Right to restriction of processing: In some cases, you may have the right to have the processing of your personal data restricted. For example, where you contest the accuracy of your personal data, it may be restricted until the accuracy is verified, or where the processing is unlawful but you object to it being deleted and request that it is restricted instead.

Right to object to processing: You may object to the processing of your personal data (including profiling) when it is based upon our legitimate interests or for the purposes of statistical analysis.

Right to object to direct marketing: You may also object to the processing of your personal data for the purposes of direct marketing, and you can do this at any time.

Right to data portability: You have the right to receive, move, copy or transfer your personal data to a controller which is also known as ‘data portability’. This only applies to information you have given us and if we are processing your personal data based on consent or contract and the processing is automated.

Right to complain: If you have any concerns about our use of your personal information, you can make a complaint to us by using the contact information provided at the start of this privacy policy. You can also complain to the ICO if you are unhappy with how we have used your data. You can contact the ICO at www.ico.org.uk, by telephone on 0303 123 1113 or by post at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

CONSEQUENCE OF NOT PROVIDING YOUR DATA

You are not obligated to provide your personal information to Loan Logics Limited, however, where this information is required for us to provide you with our services and products, by choosing not to provide it, we may not be able to offer our products or services to you.

PRIVACY NOTICE UPDATES

This notice is subject to change. Any changes made, will be updated on our website www.loanlogics.co.uk