Clearly Loans Limited of Unit 1a, The Boulevard, Blackmoor Lane, Watford, Hertfordshire WD18 8YW (“We”) are committed to protecting and respecting your privacy.
We have put in place a number of measures to ensure that any personal data we obtain from you is processed and maintained in accordance with legal requirements and the accepted principles of good information handling in accordance with the Data Protection Act 1998 (the “DPA”) and the General Data Protection Regulations (“GDPR”).
The Data Controller is Clearly Loans Limited. We determine the purposes for which and the manner in which your personal data will be processed.
2. Information we may collect from you
We will collect personal and financial information about you when you provide us with data and information over the telephone, when you or third parties (such as your broker) send us documents including an application form, when you apply for a loan and when we access information held by credit reference agencies about you. We also collect personal information when we communicate with you during our servicing of your loan agreement with us.
3. Uses made of the information
We may use information held about you in the following ways:
- To verify your identity and credit standing with credit reference agencies and to enable us to consider and process your application for a mortgage. Please note that credit reference agencies may place a search footprint on your credit file that may be seen by other lenders.
- To assess your credit history and confirm your employment details.
- To detect, prevent and investigate actual and potential fraud and related activities.
- To collect your loan repayments and other sums that may be owed by you to us.
- To contact you in connection with your application or enquiry and to provide you with ongoing account information. f) To help us administer and service your account with us.
- To help us administer and service your account with us.
When we collect your mobile telephone number and/or e-mail address, we may wish to use this information to communicate with you, using SMS text messages or e-mail, concerning any aspect relating to the administration or servicing of your account. The information we will send may include the following:
- Your name
- The account number
- The amount of any arrears
- The amount of charges applied to your account
- Your payment due dates
- The monthly payment amount
- Your outstanding balance
We will commonly communicate using such electronic means if you fall behind with payments or cancel a direct debit mandate or standing order. We will at any time cease contacting you by such means if you ask us to do so.
4. Disclosure of your information
We may disclose your personal information to the following:
- Our insurers, auditors, solicitors, professional advisors, sub-contractors or any person providing services to Clearly Loans Limited or who are involved in the loan application, who have agreed to treat your personal details as confidential.
- Any funders (or prospective funders or investors) of Clearly Loans Limited.
- Where we have decided to outsource all or part of the administration or serving of your loan to any proposed or actual third party who has agreed to keep the details confidential. d) Any person where such disclosure is necessary to enable us to ensure that your obligations under any agreement or mortgage with us is being complied with and to ensure that any security given in connection with any loan is not at risk.
We may also disclose your personal information to third parties from time to time for the following reasons:
- In the event that there is (or is to be) any change in ownership of our business or assets, we may disclose your personal data to the prospective or new owners so that they may continue to operate our business effectively and continue to provide services to our customers. This may include new shareholders or any organisation that may take an assignment or transfer of any agreements we have entered into with our customers.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation (including with any government agencies or regulators) or to exchange information with other third parties for the purposes of fraud protection and credit risk reduction.
5. The legal grounds upon which we handle your personal data
The UK’s data protection law allows the use of your personal data where its purpose is for a legitimate interest. The legitimate interests we are pursuing here comprise the following:
Promoting responsible lending decisions:
We collect personal and financial information from you and from credit reference agencies (CRAs) to help us to assess your ability to repay your loan with us.
Such information includes personal data about bank accounts, credit cards, mortgages and other agreements that involve a credit arrangement like utilities and communications contracts (including mobile and internet) and how you are meeting your payments obligations to these organisations and whether you have any court judgments. We also collect personal information about your age, family dependants, about your employment and income, whether you are on the electoral role and details about your property. We may also collect information about a business you are involved with where you are self-employed including requesting financial records, such as accounts and information held by public bodies such as Companies House.
Prevent and detect crime:
We also collect personal and financial information from you and from credit reference agencies and public or government bodies to help us to detect and prevent crime and fraud and to also verify your identity under our anti-money laundering obligations.
Servicing of your loan:
The personal information we collect about you will enable us to communicate with you about your loan and to service your account, for example to provide annual statements, to process your payments onto our systems and to contact you about any missing payments. We will make a record of our communications with you and your account activity (including recording telephone calls) to help us to monitor and manage your account, check that we are providing an adequate service and to help us to deal with any complaints.
6. Credit reference agencies
We will contact credit reference agencies to get information on your credit behaviour with other organisations as described above to help us make an assessment of your financial situation before we decide to make a loan to you. We may also collect financial information on an associate’s personal accounts if there are any financial links with you.
We will disclose information about your transactions with us and your loan performance (including any defaults) to credit reference agencies who may keep a record of that information. If you provide us with false or inaccurate information and we suspect fraud, we will record this and may also pass this information to financial and other organisations involved in fraud protection to protect us, them and our respective customers from theft and fraud.
The credit reference agency we use to collect information and file is Equifax Limited. Their details are:
You may contact them (or the other main credit reference agencies) if you want to obtain a copy of your credit file to see what information they hold about you. Further information about the credit reference agencies and what information they collect about you and how they use your personal information can be found at https://www.equifax.co.uk/crain.html
7. Retention of your personal information
The length of time we retain your information will depend on the purpose for which the information was provided. In general, however:
- We will keep the information that is necessary to enable us to manage your account and provide you with a service that you have requested for as long as it takes us to provide that service.
- We will keep your contact details for as long as we have your consent to send you marketing information.
- We will keep records of your account history for a period that will not usually exceed six years after your loan has been repaid. This is to allow us to respond to any complaints or disputes that may arise during that period.
- We will keep other information about you if it is necessary for us to do so to comply with the law or regulatory requirements.
Please be aware that credit reference agencies and fraud prevention agencies who we have transferred your data to in accordance with this notice, may also retain your information for a period of six years.
8. Data security
At Clearly Loans Limited we make your safety and security a top priority and are committed to protecting your personal and financial information. Where we collect personal information from you, we will protect that information with controls based upon recognized security standards, regulations, and industry-based best practices. Your personal information is stored in our secured servers and cloud based servers.
9. Telephone calls
When you telephone us we may record and retain your call for training and monitoring purposes.
10. Access to your information
You have the right to request a copy of the information that we hold about you (sometimes called a “subject access request”). If you would like a copy of some or all of your personal information, please email or write to us at our above address. There is no charge for this service although we can charge a reasonable fee if your request is excessive or repetitive. We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.
You are not entitled to request that the personal data we hold about you be erased unless you can show that the personal data is no longer necessary in relation to the purpose for which it was originally collected or processed by us. This is because it has been obtained in order to provide a loan to you and to service and maintain your loan account as described in 5 above and is therefore required for our legitimate interests.
You have a right to complain to us if you are dissatisfied in the way that we have handled your personal data. You may contact us for details of our complaints policy. You also have a right to complain to the Information Commissioner’s Office if you are unhappy with the way we handle your data. Their details are Customer Contact, Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF, telephone 0303 123 1113 or e-mail email@example.com. You can also download and complete a complaint form by following the link at https://ico.org.uk/concerns/
We would like to send you information in the future about our mortgage products which we think might be of interest to you. If you opt in to receiving marketing information you can still opt out at a later stage by contacting us at Unit 1a, The Boulevard, Blackmoor Lane, Watford, Hertfordshire WD18 8YW, calling us on 01923 750 777 or e-mailing us at firstname.lastname@example.org. You may do so at any time in the future. We will not share your personal information with third parties for marketing purposes.
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
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 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.html
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.
A. 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.
B. 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.
C. 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.
D. 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.
For further information visit www.aboutcookies.org or www.allaboutcookies.org. You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However in a few cases some of our website features may not function as a result.
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
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
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
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: EXP_Last_Visit
Expires: 1 Year
Description: This cookie is provided by the Expression Engine content management system and contains data regarding the dates of the users visit to the website.
Cookie name: EXP_Last_Activity
Expires: 1 Year
Description: This cookie is provided by the Expression Engine content management system and contains data regarding the dates of the users recent activity on the website.
Cookie name: EXP_Tracker
Expires: End of Session
Description: This cookie is provided by the Expression Engine content management system and contains data regarding the last 5 pages the user visited on the website and allows us to redirect the user to the page they were on before submitting a comment or sending us an email through a contact form.