The personal data we collect about you

Personal data collected, used, stored and transferred by us may include:

• Identity Data including forenames, last name, maiden name, date of birth, gender, marital status, and username or similar identifier
• Contact Data including home address, email address and telephone numbers
• Financial Data including banks statements, payment card details, savings, debts such as loans and credit cards, income & expenditure, employer & pension benefits, and other assets
• Transaction Data including payments made for products and services you have purchased from us
• Technical Data including internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices used to access the Loans Warehouse website
• Profile and Usage Data including purchases made by you, feedback and survey responses, and how you use our website, products and services

Marketing and Communications Data including your preferences in receiving marketing from us and our business partners and your communication preferences

How do we collect your personal data?

Personal data is collected by us using the following methods:

• Direct interactions with an adviser in person, by post, phone, email or otherwise when sourcing and applying for personal loan, bridging loan or second mortgage, processing Identity, Contact and Financial categories of personal data. Telephone calls are recorded for monitoring, training and regulatory purposes but not stored indefinitely.
• Automated technologies or interactions with our website, by using the web enquiry form, processing Identity, Contact, Financial and Technical categories of personal data.
• Third parties or publicly available sources (processing Identity, Contact and Financial categories of personal data) such as enquiries you may have made via our introducers.

How do we use your personal data?

We use your personal data in the following circumstances and relying on the following lawful basis for processing:

Change of purpose 

We will only use your personal data for the purposes stated above, unless we reasonably consider that we need to use it for another reason and it is compatible with the original purpose. Please contact us for an explanation as to how any new processing is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis 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.

Changes to our Privacy Notice

We keep our Privacy Notice under regular review and we will place any updates on this web page. This Privacy Notice was last updated on 17th May 2018. Historic versions can be obtained by contacting us.

Marketing

You will also have the choice to opt-in to receiving other related marketing information and related products and services.

You can opt-out of receiving these types of communications at any time by emailing enquiries@comparemyloan.co.uk or by clicking on the relevant link in email communications you receive from us.

However please note that your personal information will not be passed to any third-party organisation for marketing purposes.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal data to only those Compare My Loan staff, appointed representatives, advisers, business partners and suppliers who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Compare My Loan’s website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Sharing of personal data outside of the European Economic Area

Compare My Loan will not share your data outside of the European Economic Area (EEA) unless at your specific request or to comply with a legal duty to do so. Some of the processors we use may transfer your personal information to other territories or countries outside the EEA. If this is the case, we will ensure they take such steps as are necessary to ensure appropriate safeguards apply to maintain the same levels of protection as are needed under data protection laws in the UK.

Who we disclose personal data to

Your personal data may be shared with third parties for the following purposes:

These companies are required to ensure appropriate security measures are in place and maintain the confidentiality of your personal data, and to use your personal data only in the course of providing such services and in accordance with Loans Warehouse’s instructions.

Credit Reference Agencies

We help customers obtain finance by a number of means. In order to get a picture of your true credit position, we access and search your credit file with a credit reference agency.

We will seek your permission to complete any credit searches when they become necessary.

If you have any questions on your credit reference data, please refer to: https://ico.org.uk/media/for-thepublic/documents/1282/credit-explained-dp-guidance.pdf

For more information about how your data is managed by the credit reference agencies, you may wish to visit:

Equifax – www.equifax.co.uk/crain
Experian – www.experian.co.uk/crain
TransUnion – www.transunion.co.uk/crain

We will engage with fraud prevention agencies (including the National Crime Agency, Action Fraud and the Home Office) to protect us and our lenders from fraud and money laundering. We or our lenders may also pass information to financial and other organisations involved in fraud prevention including law enforcement agencies and CIFAS who may also access and use this information to detect, investigate and prevent crime.

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services and financing you have requested, or to employ you, 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 services, financing or employment to you. To read CIFAS’s privacy notice in full, please go to https://www.cifas.org.uk/website-privacy-notice.

Some of our lenders provide joint loans. If you tell us that you have a spouse or financial associate, they may link your records together, so you must be sure you have their agreement to disclose Information about them. Credit reference agencies link your records together with those of your financial associates and these links will remain on your and their files until you or your partner successfully file for a disassociation to break the link.

How long is your personal data retained?

We only retain your personal data for as long as necessary. The table below outlines how long data is retained, and depends on the reason the personal data is used for:

After these retention periods if there is no other on-going client relationship your personal data will either be securely deleted or anonymised so that it can be used for statistical purposes but without any method of identifying you individually.

Your rights

You have the right to:

• Request access to your personal data – This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Should you wish to make a Data Subject Access Request, you should put this in writing to us as details on our Statement of Services. We will respond to your request within 30 days.
• Request correction of the personal data – This enables you to have any incomplete or inaccurate data corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data – This enables you to ask us to delete personal data where there is no good reason for us continuing to process it. You can also ask us to delete your personal data where you have successfully objected to the processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. However, we may not always be able to delete the data for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data – where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data – This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party – We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data – However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Who do I contact?

If you have any questions or complaints relating to how we use your personal data, or if you wish to exercise any of your rights regarding your personal data, please contact us by emailing enquiries@comparemyloan.co.uk or by writing to us. We will respond to you as soon as is possible. The length of time will depend on the type and complexity of the request, but you will receive a response no later than one month from the initial request.

What if I am still not satisfied?

If you are not satisfied with how Loans Warehouse has responded to your enquiry, you have the right to complain to the Information Commissioner’s Office (ICO), who is the regulator for data protection in the United Kingdom.

Information Commissioner
Wycliffe House; Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 01625 545745
www.ico.org

Please call us on 01923 678870 if you have any queries.

COOKIES

In this section you will find information on what cookies may be set when you visit our website and how to reject or delete those cookies.

When you visit our website we want your experience to be easy, useful and reliable.  Where services are provided on the internet, this sometimes involves placing small amounts of information on your device, for example your computer or mobile phone. This information consists of small files known as cookies and they cannot be used to identify you personally.

These pieces of information are used to improve our services for you through, for example:

• Enabling a service to recognise your device so you don’t need to provide the same information several times during one task.
• Recognising that you may already have provided a username and password so you don’t need to do it for every web page requested.
• Measuring how many people are using services, so they can be made easier to use and there’s enough capacity to ensure they’re fast.

You can manage these small files yourself and learn more about them by visiting: www.direct.gov.uk/managingcookies

HOW TO CONTROL AND DELETE COOKIES

We will not use cookies to collect personally identifiable information about you.

However, if you wish to restrict or block the cookies which are set by our website or any other website, you can do this through your browser settings.

Comprehensive information on how to do this across a wide variety of browsers can be found at www.aboutcookies.org

Please be aware that restricting cookies may impact the functionality of the websites you visit.

THIRD PARTY COOKIES

Cookies set for embedded social web content

To support our information provision and engagement, we sometimes embed photos and video content from websites such as Youtube, Linkedin, Twitter, Facebook and Flickr. As a result, when you visit a page with content embedded from, for example, Youtube or Facebook, you may be presented with cookies from these websites. We do not control the use of these cookies. You should check third party websites for more information on these cookies.

Our website may also carry embedded ‘share’ buttons to enable users of the site to easily share articles with their peers through a number of popular social networks. These sites may set a cookie when you are also logged in to or otherwise using their service. We have no control over these cookies and you should check for more info from their website on these cookies.

Cookies for web analytics

We use third party services to gather data regarding the usage of our site on our behalf using cookies, log file data and code which is embedded on our website. We use this type of information to help improve the service we provide to UK and non UK visitors.

Google analytics

Google analytics is a web analytics service provider provided by Google Inc. Google analytics sets a cookie in order to evaluate a visitor’s use of our website.

Google stores the information collection by the cookie on their servers in the United States. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using our website, you consent to the processing of data about you by Google in the manner and the purposes set out above.

For more information on the cookie set by Google analytics, including information on how to opt out please go to www.google.com/intl/en/privacypolicy

Cookie Categories

The type of cookie used on this Site can each be put into 1 of 4 categories, based on the International Chamber of Commerce guide to cookie categories.

1. Strictly Necessary Cookies: These cookies are essential, as they enable you to move around a website and use its features, such as accessing secure areas. Without these cookies, services you’ve asked for (such as access to secure areas) cannot be provided. These cookies don’t gather information about you that could be used for marketing or remembering where you’ve been on the internet. These cannot be restricted or blocked.
2. Performance Cookies: These cookies collect information about how you use a website, for example which pages you go to most often and if you get any error messages from certain pages. These cookies don’t gather information that identifies you. All information these cookies collect is anonymous and is only used to improve how a website works. These cookies are not used to target you with online advertising. Without these cookies we cannot learn how our website is performing and make the necessary improvements that could enhance your browsing experience. These can be restricted or blocked.
3. Functionality Profile Cookies: These cookies allow a website to remember choices you make (such as your user name, language or the region you are in) and tailor the website to provide enhanced features and content for you. For instance, they remember your log-in details and allow you to watch videos. They also ensure the onsite marketing and experience is relevant to you. These cookies can also be used to remember changes you’ve made to text size, font and other parts of pages that you can customise. The information these cookies collect may be anonymous and they cannot track your browsing activity on other websites. Without these cookies, a website cannot remember choices you’ve previously made or personalise your browsing experience. These can be restricted or blocked.
4. Targeting Cookies: These cookies gather information about your browsing habits. They remember that you’ve visited a website and share this information with other organisations such as advertisers. They do this in order to provide you with ads that are more relevant to you and your interests. Although these cookies can track your visits to other websites, they don’t usually know who you are. Without these cookies, online advertisements you encounter will be less relevant to you and your interests. These can be restricted or blocked.

COOKIES WE USE

This is a list of the main cookies we use and what each is used for:

Cookie name: __utma
Expires: 2 years
Category: Performance

Description: Used by Google Analytics. Each unique browser that visits a page on the site is provided with a unique ID via the __utma cookie. In this way, subsequent visits to the website via the same browser are recorded as belonging to the same (unique) visitor. Thus, if a person interacted with the website using different browsers, the Analytics reports would track this activity under two unique visitors.  Similarly if the same browser were used by two different visitors, but with a separate computer account for each, the activity would be recorded under two unique visitor IDs. On the other hand, if the browser happens to be used by two different people sharing the same computer account, one unique visitor ID is recorded, even though two unique individuals accessed the site.

Cookie name: __utmb & __utmc  
Expires: 30 min
Category: Performance

Description: Google Analytics uses these two cookies to establish a session. If either of these two cookies is absent, further activity by the user initiates the start of a new session.

Cookie name: __utmz   
Expires: 6 months
Category: Functionality

Description: When visitors reach the site via a search engine result, a direct link, or an ad that links to the page, Google Analytics stores the type of referral information in a cookie. The parameters in the cookie value string are parsed and sent in the GIF Request (in the utmcc variable). The expiration date for the cookie is set as 6 months into the future. This cookie gets updated with each subsequent page view to the site; thus it is used to determine visitor navigation within the site.

Cookie name: PHP_Session ID       
Expires: End of session
Category: Functionality

Description: This cookie is a unique identifier for a session. It identifies a user’s session e.g. secure area log ins, email subscriptions.

Cookie name: __atuvc   
Expires: 2 years
Description: This cookie provides integration with social media accounts by using ‘AddThis’ (www.addthis.com) for users that choose to share content on their social media networks.

Cookie name: _ceir, is_returning
Expires: 5 years
Description: Track whether a visitor has visited the site before

Cookie name: _CEFT
Expires: 1 year
Description: Store page variants assigned to visitors for A/B performance testing

Cookie name: _ceg.s
Expires: 3 months
Description: Track visitor sessions

Cookie name: _ceg.u
Expires: 3 months
Description: Track visitors on your site

Cookie name: s
Expires: 3 months
Description: Track visitor sessions

Cookie name: u
Expires: 3 months
Description: Track visitors on your site

Cookie name: cer.s
Expires: Session (expires when the browser is shut down)
Description: Visitor activity recording session unique ID, tracking host and start time

Cookie name: cer.v
Expires: Up to 31 days (expires on the first of the month)
Description: Visitor activity recording unique ID, visit time and visit count

The following table illustrates the possible tracking cookies that the Lucky Orange tracking script might set:

Cookie name: _global_lucky_opt_out
Lifetime: 10 years
Purpose: If set, will not run Lucky Orange. Set via our opt out links.

Cookie name: _lo_np_<Poll ID>
Lifetime: 30 days
Purpose: Set if a user should no longer receive a particular poll.

Cookie name: _lo_bn
Lifetime: 30 days
Purpose: Indicated this visitor has been banned from tracking.

Cookie name: _lo_cid
Lifetime: Session
Purpose: ID of the visitor’s current chat, if any.

Cookie name: _lo_uid
Lifetime: 2 years
Purpose: Unique identifier for the visitor.

Cookie name: _lo_rid
Lifetime: 30 minutes (extending)
Purpose: ID of the visitor’s current recording.

Cookie name: _lo_v
Lifetime: 1 Year (extending)
Purpose: Total number of visitor’s visits.

Cookie name: __lotr
Lifetime: 180 days
Purpose: URL of the visitor’s original referrer, if any.