Privacy Policy

Last updated May 2018

This privacy notice is to let you know how Lendable gathers and processes your personal information in accordance with this privacy notice and in compliance with the relevant data protection regulation and law. This document applies to both borrowers and investors on the Lendable platform.

This notice provides you with the necessary information regarding your rights and obligations, and explains how, why and when we collect and process your personal data. You should not use this website or our services if you do not accept this Privacy Policy or our Terms of Use.

We are committed to ensuring that your personal data is kept safe and we have put in place appropriate technical and other security measures to protect it.

To make enquiries or exercise any of your rights set out in this Privacy Policy, please contact us at contact@lendable.co.uk.

Who are we?

We are Lendable Limited, our registered office is at 128 Shoreditch High Street, London, E1 6JE and we are registered in England and Wales under company number 08828186. We are registered on the Information Commissioner's Office (ICO) Register of Data Controllers under registration number ZA041704. Our designated Data Protection Officer is Paul Pamment.

We can be contacted by post at 128 Shoreditch High Street, London, E1 6JE by email at contact@lendable.co.uk or by phone on 020 3322 1948.

  • How do we collect personal information?

    We collect personal data about you in the following ways:

    • directly from you when you fill in forms on our site, manage your loan online or correspond with us by email, phone or otherwise;
    • by observing how you access and use our products and services. For example, how you use our website or how you manage your accounts and services provided by Lendable;
    • from 3rd party organisations such as Credit Reference and Fraud Prevention Agencies and other data providers;
    • from organisations that have your consent, or a separate legal basis, to share data with us for a specific and defined purpose. This could include for direct marketing or assessing your eligibility for a partner's product; and
    • from public sources, for instance the Companies House register, the insolvency register, the ‘Open Register’ which is an extract of the electoral register and search engine results.
  • What personal information do we collect?

    We may hold and use various categories of personal information collected at the start of, and for the duration of your relationship with us. We will limit the collections and processing of these personal data to what is necessary to achieve the purposes identified in this notice. It is your responsibility to ensure that all information you provide to us is correct, accurate, complete and not misleading.

    Personal information may include:

    • personal details including your name, address, phone numbers, email address, date of birth, employment status and home ownership details;
    • financial and banking information including account details and transactional information;
    • demographic and lifestyle information;
    • information collected from Credit and Fraud Prevention agencies at the point you first enquire about your loan and on an ongoing basis as we manage your loan;
    • details of the loan(s) you hold and have held with us including all their transactions;
    • details of any contacts that we have had with 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; and
    • information collected through customer feedback surveys.

    In some circumstances we may also collect and process certain special categories of information. This includes ensuring our services are accessible, to detect and prevent financial crime or to protect vulnerable customers. We will only collect and process special category data with your explicit consent.

  • How do we use your personal information?

    We may use your information:

    • to process and complete your application for a loan;
    • to search Credit Reference Agencies’ and Fraud Prevention Agencies’ records;
    • to make an initial lending decision and to assess your eligibility for additional borrowing;
    • to set up and process payments and prevent fraudulent transactions;
    • to communicate effectively with you when applying for, agreeing to and undertaking the loan contract, to effectively answer and manage any questions, concerns or complaints you may have through all necessary channels;
    • to update our records and maintain your account with us;
    • 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 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 if we cannot contact you;
    • to recover any debt you owe us;
    • to comply with our legal and regulatory requirements; for any other specific purpose which we notify you of at the time your personal information is collected;
    • to pre-populate fields on our site to make it easier for you to navigate when you return to our website and login as an existing customer;
    • to issue tax documentation to investors.

    To understand our customers’ needs better, we will, with your permission, retain the information you have provided us to analyse customer trends and behaviour.

    We monitor or record calls, emails, sms and other communications for business purposes only, such as for security, quality control and training.

    If we cannot offer you a product, we may check your eligibility for loans and/or other relevant credit products from our panel of trusted lenders and brokers. We will always seek your consent to do this and our partners will always use soft checks which will not impact your credit file. Our partners include:

  • Why do we process your personal information?

    We will only collect and use your personal information where it is necessary for us to carry out our lawful business activities. Our grounds for processing your data are as follows

    Contractual necessity

    We may process your information where it is necessary to enter into a contract with you or to perform our obligations under that contract. This may include processing to:

    • Assess your eligibility for the products and services we provide, and
    • Provide and administer the products we offer, including:
      • setting up your account;
      • verifying your contact information;
      • collecting and issuing necessary information and documentation;
      • processing payments and disbursing money;
      • issuing statements, formal notices;
      • to manage fees, charges and interest due on your account;
      • to send service communications and statutory notices;
      • to collect and recover outstanding sums owed to us; and
      • to address any enquiries or complaints we receive from you or a representative you have appointed.
      • to issue tax documentation to our investors
    Legal obligation

    We may process your data where it is a legal or statutory obligation. This may include processing to:

    • confirm your identity;
    • detect, investigate and report transactions in order to comply with laws relating to money laundering, financial crime and international sanctions;
    • assess affordability of any credit products for which you apply;
    • detecting, investigating and reporting financial crime, and taking measures to prevent this;
    • maintain records of our business as required by law, e.g. creating and keeping record of company accounts;
    • complying with laws which require us to provide information, directly or indirectly to any national authority, for the purpose of calculating and collection of tax;
    • responding to enquiries and requests for information by any of our Regulators;
    • creating and submitting reports required by any of our Regulators;
    • to otherwise meet our obligations under all laws and regulations based on law which apply to our business activities; and
    • where we have a duty to protect vulnerable customers.
    Legitimate interest

    We may process your information when we have a business or commercial reason to do so. If we do, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is. This may include processing to:

    • develop new products and services;
    • statistical analysis, analytics and profiling, for example, to create scorecards, models and variables in connection with the assessment of credit, fraud, risk or to verify identities, to monitor and predict market trends, and for analysis such as loss forecasting;
    • 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 assess how our customers use our website, products and services;
    • maintain and develop our business systems, including without limitation, testing and upgrading them;
    • assess your eligibility for Top Up loans; and
    • to obtain finance for the products we provide.
  • Who do we share your personal information with?

    We may use third party companies to provide services on our behalf. This may require these organisations to access and process your personal data.

    • Credit Reference Agencies;
    • Fraud Prevention Agencies including CIFAS;
    • communications service providers offering mail, email and SMS text services;
    • Debt Collection Agencies and Debt Management Companies;
    • debt purchasers;
    • customer survey providers in order to receive feedback and improve our services;
    • IT service providers;
    • legal services;
    • digital marketing service providers;
    • direct marketing service providers;
    • payment processors;
    • trusted lenders and brokers who will assess your eligibility for their products;
    • any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries; and
    • debt and equity investors who help us finance the products we provide.

    One of our communications service providers that we use to send customer emails is located in the USA and is covered by Privacy Shield. Data in or attached to these emails will be processed outside the EEA. It may also be processed by staff operating outside the EEA who work for our provider.

    By submitting your personal data, you agree to this processing. We will take all steps reasonably necessary to ensure that your data is treated securely in line with this privacy policy.

    For more information about these controls, please visit https://ico.org.uk and search for ‘International transfers’.

  • How do we use Credit Reference Agencies?

    To process your application, we will perform credit and identity checks on you with one or more credit reference agencies (“CRAs”). Where you take services from us we may also make periodic searches at CRAs to manage your account with us. To do this, we will supply your personal information to CRAs and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information 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);
    • trace and recover debts; and
    • ensure any offers provided to you are appropriate to your circumstances.

    We will continue to exchange 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 may be 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 such time as you or your partner successfully file 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 information, data retention periods and your data protection rights with the CRAs are explained in more detail at https://www.callcredit.co.uk/crain. CRAIN is also accessible from each of the three CRAs – clicking on any of these three links will also take you to the same CRAIN document:

  • How do we work with Fraud Prevention Agencies?

    Before we provide services, goods or financing to you, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you.

    The personal data you have provided, we have collected from you, or we have received from third parties will be used to prevent fraud and money laundering, and to verify your identity

    Details of the personal information that will be processed include, for example: name, address, date of birth, contact details, financial information, employment details and device identifiers including IP address.

    We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

    We process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested.

    Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

    CONSEQUENCES OF PROCESSING

    If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services or 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. If you have any questions about this, please contact us on the details above.

    DATA TRANSFERS

    Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.

  • What Cookies and other technologies do we use?

    We may use cookie technology on our website to collect some of the information detailed in this policy.

    Cookies are small text files stored on your device or internet browser when you visit us. We use cookies mainly to improve the performance of the Lendable website and our service for customers.

    Our Cookie Policy explains in more detail what types of cookie we use, why we use them and how to identify and disable them, but please be aware that some of our services will not function as smoothly if your browser disables all cookies.

    When a visitor requests any page from our web site, our web servers automatically obtain that visitor's domain name and IP address. This information does not contain sensitive data about our users and is critical to the functioning of all websites. An IP address serves as the return address, much like a post code, of your device when you request to see a webpage which allows us to send the information you want back to you. We only use this data to investigate and prevent fraud or abuse of our website.

    This site uses the web analytics service called Inspectlet. Inspectlet can record user clicks, movements, scrolling and selected non-personal text users enter into our website. The service does not gather personally identifiable information. We use this service to improve our website, make it more user-friendly and monitor that everything is performing as well as possible.

    As part of our commitment towards transparency and customer data privacy, we need to ask for your consent to set the marketing cookies described in our cookie policy. When you arrive on our website you will be asked for your consent to place these cookies on your device, 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 or navigating to our Cookie Policy.

  • How can you amend your preferences?

    Any electronic marketing communications we send you will include clear and concise instructions to follow should you wish to unsubscribe at any time. You may also amend your contact preferences in the following ways:

  • What are your personal data rights?

    As a data subject, you have a number of rights:

    • the right to access the personal data we hold about you;
    • the right to rectify inaccurate personal data or complete it if it is incomplete;
    • the right to have your personal data deleted;
    • the right to request restriction of or suppression of your personal data;
    • the right to obtain and reuse your personal data for your own purposes across different services (“portability”);
    • the right to object to the processing of your personal data in certain circumstances; and
    • rights related to automated decision making including profiling.

    If you would like to exercise any of the rights outlined above, you can make a request verbally by calling 020 3322 1948 or in writing by emailing contact@lendable.co.uk.

    Your data protection rights are subject to certain restrictions and conditions. We will assess your request, if we decided not to act upon it or place certain restrictions, we will inform you of our reasons for this. We will not make a charge for handing your rights request.

    You have the right to complain to us and to the data protection regulator; the Information Commissioner’s Office. Their address is: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. They can be contacted by phone on 0303 123 1113 (local rate) or 01625 545745 if you prefer to use a national rate number.

    You can find details on how to report a concern at: https://ico.org.uk/reportaconcern

  • How long do we keep your personal information?

    Unless required or permitted by law, we only retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy or until you request it is deleted. Even if we delete your personal information it may persist on backup or archival media for legal, tax or regulatory purposes.

  • How do we use automated decisions?

    We may use your personal data in automated processes to make decisions about you. You have the right not to be subject to a decision based on solely automated processing, if this will have a legal or other significant effect on you (certain exceptions apply).

    We use automated decision making in:

    • credit scoring and affordability assessment. We use data collected from yourself through online forms, your usage of our site and Credit Reference Agencies and other 3rd parties to assess your creditworthiness and affordability of the product applied for. You have the right to appeal the outcome of these automated decisions;
    • fraud and money laundering risk identification. We may automatically decide that you pose a fraud or money laundering risk if our processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct, or is inconsistent with your previous submissions, or you appear to have deliberately hidden your true identity
    • we may use your personal data in profiling to identify whether you are suitable for products and services we offer and to inform you of these. This profiling will be conducted by ourselves when assessing suitability of existing customer for top up offers. We will use profiling in conjunction with our partners when developing new prospect marketing campaigns.
  • How do we link to other sites?

    Our website may contain hyperlinks to websites that are not operated by us. We urge you to review any privacy policy posted on any site you visit before using the site or providing any personal information about yourself.

© Lendable 2018