Last updated March 2016
1. Who we are
Lendable is operated by Lendable Ltd (“we”, “us”) (company number 08828186), registered office 128 Shoreditch High Street, London, E1 6JE. Lendable Ltd is registered with the Information Commissioner’s Office in compliance with the Data Protection Act 1998 under registration number ZA041704.
We and our carefully selected third party partners will only use your personal information to ensure that we deliver an excellent service to you, and to process and deliver your services and maintain your account with us.
Personal information means any information which identifies you, and may include information such as your name, email address, telephone number and position.
As is the case with many organisations, communications by telephone may be recorded for the purposes of monitoring our customer service standards, training and for security purposes.
4. Information we hold about you
We may hold and use the following information about you:
- your name, address, phone numbers, email address, date of birth, employment and banking and financial details;
- demographic and lifestyle information;
- information we receive when making a decision about you, your loan or application (including information collected from Credit Reference Agencies);
- details of the loans you have and have had with us and all transactions;
- details of when you contact us and when we contact you;
- details of how you applied for your loan (for example which browser you applied with);
- records of any telephone, email or other communication with you.
together with any other information which we reasonably need to operate your account, make decisions about you or fulfil our regulatory obligations.
5. Our use of your information
Any personal information we collect from you will be used in accordance with the Data Protection Act 1998 and other applicable laws.
When we ask you for personal information we may use it for the following purposes:
- to process and complete your requests and/or applications for loans and/or services and communicate with you about our products and/or services;
- to search Credit Reference Agencies’ and Fraud Prevention Agencies’ records (including information from overseas);
- make, or assist in making, credit decisions about you, including (without limitation) to assess and process your loan application (we may retain a record of your information for a reasonable period of time following the end of our loan approval process for administration purposes);
- to process payments and prevent fraudulent transactions (we may retain your details (including your credit/debit card information) for these purposes for a reasonable period of time and we may pass your details to a third party to carry out these functions);
- to update our records and maintain your account with us;
- to obtain finance for the loans we provide through the website;
- to recommend offers for products and/or services that may be of interest to you, where you have consented to be contacted for such purposes;
- to administer the website services, including processing any searches or requests for information about our products or services;
- to 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;
- to maintain and develop our business systems, including without limitation, testing and upgrading them;
- to trace your whereabouts;
- to recover any debt you owe us;
- to check any instructions given to us;
- to comply with our legal and regulatory requirements;
- to check your eligibility for loans and/or other relevant credit products, if we are unable to approve your loan application, with partnered lenders, who will perform a soft credit check to provide a credit offer;
- to introduce you to the services of TotallyMoney.com if we are unable to approve your loan application. They will search the loan market for alternative loan providers and their service is totally free;
- to introduce you to the services of Choose Wisely if we are unable to approve your loan application. They will search the loan market for alternative loan providers and their service is totally free. Lendable may receive a commission from Choose Wisely should your loan application be successful; and
- for any other specific purpose which we notify you of at the time your personal information is collected.
If you provide us with any debit card or bank account details, either during the loan application or subsequently, we will keep those details and may use the details to take further payments both on your current loan and on any subsequent loans, unless you advise us otherwise.
With a view to understanding our customer's needs better, we will, with your permission, retain the information you have provided us to enable us to offer products and services that are likely to be of interest to you. If you have indicated that you would like us to, we may also pass your information onto carefully selected third parties who may inform you about their products and services which may be of interest to you.
If you want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data.
This will include the transfer of your details to TotallyMoney.com who may be able to find you an alternative loan provider, if we are not able to approve your application to us. TotallyMoney.com will conduct a soft search on your credit file with the Credit Reference Agencies to source alternative loan providers who meet your requirements. This search will not be seen by lenders and will not affect your credit score.
6. How we collect your information
We may collect and process your information in the following ways:
- details of transactions you carry out through our website or when telephoning us and of the fulfilment of your orders;
- if you contact us, we may keep a record of that correspondence or telephone records;
- if you complete any surveys that we have provided to you for research purposes;
- information that you provide by filling in forms on our website for transactional or any other purposes;
- details of your visits to our website and the resources that you access; and
- from outside sources such as Credit Reference Agencies and customer service providers to help us with customer verification and credit-related decisions.
7. Disclosure of your information
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries. We share personal data for crime and fraud prevention and the apprehension and prosecution of offenders. We may also disclose your personal information:
- to our suppliers (including service and content providers), contractors, agents, investors and business partners who help us administer the website and provide finance for the loans we provide through the website;
- to organisations or agencies which provide services to us, such as credit reference agencies, debt collection agencies, promotion and advertising agencies and consumer research agencies;
- if false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies to prevent fraud and money laundering. Further details explaining how the information held by fraud prevention agencies may be used can be obtained by contacting our customer support through firstname.lastname@example.org or by calling us on 020 3322 1948;
- to anyone who hosts or maintains data centres, service platforms and other infrastructure and systems on behalf of us or any member of your group, where your personal information is processed and/or stored;
- in the event of our flotation on a stock exchange, sale, merger, reorganisation, dissolution, disposal of all or part of our assets or similar event;
- to third parties for the purposes of fraud protection, credit risk reduction and debt collection;
- to our professional advisers;
- to partnered lenders who may provide you with an alternative credit offer if we are unable to approve your loan application;
- where you have otherwise consented; or
- as otherwise required or authorised by law.
Please be aware that credit reference and fraud prevention agencies may share your personal information with other organisations (including lenders and insurance companies) who will use your personal information for credit and insurance assessments (including making decisions about handling claims in connection with all types of insurance), for debt tracing, and to prevent fraud and money laundering. Credit reference and fraud prevention agencies may also use your personal information for statistical analysis about credit, insurance and fraud. Please also note that credit reference and fraud prevention agencies will keep a record of our search which may be used by others to make decisions about you and members of your household and for other purposes set out in this clause. If you give us false or inaccurate information and we suspect fraud, this will be recorded.
8. Credit Reference Agencies and Fraud Prevention Agencies
When you apply to us for a loan, we will check the following records about you (and others where applicable):
- our own;
- those held by Credit Reference Agencies;
- those held by Fraud Prevention Agencies.
Whether or not your loan application is successful, when Credit Reference Agencies receive a search from us they will place a soft search footprint on your credit file that may be seen by other lenders. Large numbers of applications within a short time period may affect your ability to obtain credit. This is applicable whether your application is accepted or declined.
They, and we, may also link your records with those of your financial associate(s) including any previous and subsequent names. These links will remain on your and their files until you or they tell the agency you are no longer financially linked and the agency accepts this. This is called a “disassociation”. If you need to request a disassociation, please contact the Credit Reference Agencies directly at the contact details set out below.
Credit Reference Agencies supply us with public information (including the electoral register, county court judgements and bankruptcies) and shared credit and fraud prevention information including information about previous applications and the conduct of your accounts in your and your financial associate(s)’ name(s).
We may also make searches at Credit Reference Agencies and Fraud Prevention Agencies to manage our relationship with you.
We will send the information that you submit through our website to Credit Reference Agencies. This information will be recorded by them. We and other organisations may access and use this information to prevent fraud and money laundering and Credit Reference Agencies and Fraud Prevention Agencies may use your information for statistical analysis. Information held by Credit Reference Agencies and Fraud Prevention Agencies will be disclosed to us and to other organisations in order to (for example):
- prevent fraud and money laundering and to check and assess applications for credit, credit related or other facilities;
- recover debts that you owe and trace your whereabouts;
- manage credit accounts and other facilities and decide appropriate credit limits;
- verify your identity;
- make decisions on credit and other facilities for you, your financial associate (s), members of your household or your business;
- check details on proposals and claims for all types of insurance; and
- check details of job applicants and employees.
When you borrow from us, we will give details of your loan and how you manage it to the Credit Reference Agencies. If you borrow and do not repay in full and on time, the Credit Reference Agencies will record the outstanding debt and, in some cases, the length of time that the debt remains outstanding. Other organisations may see these updates and this may affect your ability to obtain credit in the future.
If you fall behind with your payments and a full payment or satisfactory proposal is not received within 28 days of a formal demand being issued, then a default notice may be recorded with the Credit Reference Agencies. Any records shared with Credit Reference Agencies will remain on file for 6 years after your account is closed, whether any outstanding sums have been settled by you or as following a default.
This information may be supplied to other organisations by Credit Reference Agencies and Fraud Prevention Agencies to perform similar checks and to trace your whereabouts and recover debts that you owe.
If you give us false or inaccurate information and we have reasonable grounds to suspect fraud or we identify fraud we may record this and may also pass this information to Fraud Prevention Agencies and other organisations involved in crime and fraud prevention including law enforcement agencies who may then access this information. We and other organisations may access and use, from other countries, the information recorded by fraud prevention agencies.
The Credit Reference Agency that we use is Callcredit Information Group Limited.
The Fraud Prevention Agencies that we use are Callcredit Information Group Limited and CIFAS.
If you have any further questions about our use of Credit Reference Agencies or Fraud Prevention Agencies (or would like to receive details of these agencies) please email us at email@example.com or call us on 020 3322 1948.
9. Anonymous data collected through this website
In addition to the information we collect as described above, we use technology to collect anonymous information about the use of our website. For example, our web server automatically logs which pages of our website our visitors view, their IP addresses and which web browsers they use. This technology does not personally identify you - it simply enables us to compile statistics about our visitors and their use of our website.
Our website contains hyperlinks to other pages on our website. We may use technology to track how often these links are used and which pages on our website our visitors choose to view. Again this technology does not identify you personally - it simply enables us to compile statistics about the use of these hyperlinks.
10. Cookies and similar technologies
In order to collect the anonymous data described in the preceding paragraph, we may use cookie technology on our website.
A cookie is a small piece of information which is sent to your browser and stored on your computer's hard drive, mobile phone or other device.
You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not. However, some of the services and features offered through our website may not function properly if your cookies are disabled.
We use two types of cookies on our website:
a. Strictly necessary cookies
These cookies are essential in order to enable you to move around the website and use its features. Without these cookies, services you have asked for cannot be provided. They are deleted when you close the browser.
b. Performance cookies
These cookies collect information in an anonymous form about how visitors use our website. They allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it.
We may also use your IP address to help diagnose problems with our server, to administer our website and to improve the service we offer to you. An IP address is a numeric code that identifies your computer on a network, or in this case, the internet. Your IP address might also be used to gather broad demographic information.
We may perform IP lookups to determine which domain you are coming from (e.g. aol.com, yourcompany.com) to more accurately gauge our users' demographics.
Information from these types of cookies and technologies or about website usage is not combined with information about you from any other source. None of the cookies or technologies that we use will personally identify you.
To comply with current legislation, we need to ask for your consent to set the performance cookies described above. When you arrive on our website you will be asked for your consent to place performance cookies on your device and stating that if you continue to use our website you consent to the placing of such cookies. If you, or another user of your computer, wish to withdraw your consent at any time, you can do so by altering your browser settings.
12. Your Rights
We will not keep your personal information processed by us for any purpose or purposes for longer than is necessary for that purpose or for those purposes. The Data Protection Act 1998 gives you the right to access information held about you. Your right of access can be exercised in accordance with the Data Protection Act 1998. Any access request may be subject to a fee to meet our costs in providing you with details of the information we hold about you.
You have a right to request Credit Reference Agencies to provide you with information that they hold about you. You must contact them directly to do this and a fee may be payable.
13. Links to other websites
If you no longer wish to receive emails from us and want to be removed from our electronic mailing list, please email us at firstname.lastname@example.org with “Email Unsubscribe” in the subject heading.
You may also wish to write to us at the address given in section 1 above.
If you choose to unsubscribe from our mailing lists, we will hold your contact details on file marked so that we do not contact you again. This is so that we do not contact you if your details are subsequently provided to us by a third party.
15. Where we store your information
16. Your questions