Information you give us
This is information about you that you give us by filling in forms on our site or by corresponding with us by phone, email or otherwise. It includes information you enter when checking your eligibility for a loan and any subsequent loan application and when setting up your online account with us. Additionally, it includes any information you give us for the purposes of entering a competition or promotion, submitting a survey, or reporting a problem with our site. The information you give us will include:
- Full name and personal details including contact information such as your home address and address history, email address, home, and mobile telephone numbers.
- Your Date of Birth.
- Financial information – such as your income and expenditure which is used to enable us to make a decision regarding your eligibility and affordability for a loan with us. Additional information on your income and expenditure may be required throughout the duration of the loan in order to ensure your repayments remain affordable.
- Proof of identification.
- Bank account details.
- Throughout our relationship we will collect information relating to how you operate and manage your account including payments made.
- If you call our customer service team, we’ll automatically collect the following information:
- the phone number used to call our customer services team
- a recording of all inbound and outbound calls
- Any other information you provide to us directly.
How do we use the information we collect from you?
To enter into and perform our obligations under a contract with you:
- In order to take steps necessary to assess whether we can enter into a contract with you and, if your application is successful, in order to perform our contract with you. This includes processing your applications, assessing eligibility for loans, credit, and fraud checks, managing your account, carrying out our obligations to you and providing you with our products and services.
- To deal with any legal queries relating to your use of our service.
- To maintain business and service continuity.
- To provide you with service communications so that you receive a full and functional service and so we can perform our obligations to you, for example to send you an annual statement. These service communications may be sent by email, post, WhatsApp, text or, if the circumstances require it, we may contact you by phone. These will include notifications about changes to our service and information about the services you are using, including payment reminders sent by text message.
Where we have your consent:
- If we are unable to provide you with a loan, with your consent, we may pass your data to a third party who will assess the information you have provided against their panel of providers to see if another lender may be able to offer you a loan. At the point at which you need to consent to this you will be provided with a link to see how they will use your data.
For your legitimate interests or those of other persons and organisations:
To provide you with marketing communications by email and SMS where you have not opted out of us doing so including:
- Information about other goods and services we offer that are similar to those that you have already purchased or enquired about, including additional borrowing and products you may be eligible to apply for, including Top Up loans. You can unsubscribe from receiving marketing materials by e-mail and SMS at any time by using the unsubscribe links in each communication or by contacting us as detailed below.
- We may send you marketing materials by post. If you do not wish to receive these, you can object to receiving these at any time by phoning us on 0208 080 6450, visiting our contact page or by writing to us at Oakbrook Finance, The Poynt North, 45 Wollaton Street, Nottingham, NG1 5FW. We will cease sending marketing communication to you by post upon receipt of you raising an objection.
- To defend against or exercise legal claims and to deal with complaints.
To comply with legal requirements relating to:
- the provision of products and services;
- data protection;
- health and safety;
- anti-money laundering;
- fraud investigations;
- assisting law enforcement; and
- any other legal obligations placed on us from time to time.
Information we collect from your use of our site
With regard to each of your visits to our site we will automatically collect the following information:
- Technical information - such as the Internet protocol (IP) address used to connect your device to the Internet, whereabouts you connected to our service, your internet service provider (ISP), and what type of device you are using to access our service.
- Information about your visit, such as how you interact with our site, how long you spend on each page and the page response times, any error information and your clickstream to, through and from our site. For example, we use services to understand how you and other users navigate around the pages on our site. One such service we use is Hotjar. Hotjar records how you use our site (e.g. scrolling, clicking) but the data recorded is anonymised. We also use tools like Google Analytics to monitor information such as the clickstream to and from our site.
- For the purposes of monitoring the success of any advertising campaigns we use tools like Adalyser.
- Information we may gather through your use of your online account with us. It relates to the way you use our site and your online account, such as the pages you navigate to, time and duration of logins.
How do we use information collected about you when you use our site?
To enter into and perform our obligations under a contract with you:
- To allow you to participate in interactive features of our service, when you choose to do so.
- As part of our efforts to keep our site safe and secure.
- For fraud identification and prevention.
- If you apply for a loan information regarding your use of our site is used as part of our automated decision-making process.
In our legitimate interests of providing the best service and improving and growing our business we will process information in order to:
- Measure or understand the effectiveness of advertising we serve to you and others to deliver relevant advertising to you.
- Improve our site to ensure that content is presented in the most effective manner for you and for your device.
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- For the purpose of improving our service to you, to ensure that content from our site is presented in the most effective manner for you and for your device.
To comply with legal requirements
- For fraud identification and prevention.
Information we receive about you from other sources
We receive information about you from other sources such as:
- Information passed to us by partners, such as price comparison websites, so that we can assess your suitability for our products. This may include name, date of birth, contact information, employment details, income and expenditure, residential status and bank transactions (where consent has been given on the partner site.
- Credit Reference and Fraud Prevention agencies. The information they provide us with may include electoral roll information, payment details and outstanding balances for other accounts, details of any County Court Judgements and your credit rating.
- Your current bank or building society. In certain circumstances we may ask for permission to obtain transactional data about you from your bank. Your consent will always be required for this prior to us obtaining this information. This service is provided by Consents Online.
- Payment providers who will supply us with information about Debit or Credit Card payments you make towards your loan.
- Tracking information regarding e-mail delivery, open rates and click through rates.
Information we exchange with third parties
For the purposes set out above about how and why we collect information about you, we will exchange your personal information:
To enter into and perform our obligations under a contract with you:
- Credit Reference Agencies – We will perform credit and identity checks with one or more Credit Reference Agencies. We will supply them with your data and they will give us data about you. When you obtain a quote from us we carry out a search, this is called a quotation search and is not visible to other lenders. If you proceed with your application and a full search is undertaken this will be visible to other lenders. We will continue to exchange information about you with the Credit Reference Agencies for the duration of our relationship. This will include details on how you manage your account, the balance outstanding and whether your payments are made on time or not. We will use this information when considering whether to offer you further borrowing for example Top Up loans. Further information about how information is exchanged with Credit Reference Agencies can be found in the Credit Reference Agency Information Notice (CRAIN) which can be accessed via:
- Fraud Prevention Agencies – To help us decide whether to enter into the Agreement or any future agreement with you, and to administer and enforce the Agreement, you acknowledge that we may undertake whatever searches and enquiries and obtain whatever references or other information we consider necessary, including carrying out searches with credit reference agencies and 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 includes, for example: name, address, date of birth, contact details, financial information, employment details, device identifiers including IP address and vehicle details.
- 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.
- As part of the processing of your personal data, decisions may be made by automated means. This means 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. You have rights in relation to automated decision making: if you want to know more please contact us using the details below.
- 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.
Fraud prevention agencies may allow the transfer of your personal data outside of the UK. This may be to a country where the UK Government has decided that your data will be protected to UK standards, but if the transfer is to another type of country, then the fraud prevention agencies will ensure your data continues to be protected by ensuring appropriate safeguards are in place.
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. Your Rights
Your personal data is protected by legal rights, which include your rights to object to our processing of your personal data; request that your personal data is erased or corrected; request access to your personal data.
For more information or to exercise your data protection rights, please contact us using the contact details below.
You also have a right to complain to the Information Commissioner’s Office which regulates the processing of personal data.
- Your current bank or building society – Where you consent to your bank or building society providing us with information about your account we will use this information to help us build a profile of you in order to assess your eligibility for a loan, verify your identity and assess your affordability.
- Payment Providers – we will use information received about you from our payment providers in money laundering prevention and to allocate your payments to your account. Any payment transactions will be handled by our third party payment provider and encrypted. We will never store your Credit or Debit Card details ourselves
- Debt Collection Agencies – In some circumstances, if you default on your loan with us we may pass your information to Debt Collection Agencies to collect payments on your account on our behalf.
- Any member of our group – which means our subsidiaries, our ultimate holding company and its subsidiaries. This includes BC India whom we outsource various administrative tasks to, for example changing payment dates. This will involve them having access to your personal data. Please see the Transfer of Data outside the EEA section below for information about measures used to secure your personal data as part of this arrangement.
- Legal and professional advisors including our auditors.
- Funders whom we have an obligation to report to.
- Business partners subsidiaries, suppliers and sub-contractors for the performance of any contract we enter into with you.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site.
- Customer survey providers to receive feedback and improve our services.
For your legitimate interests or those of other persons and organisations:
- Information we obtain about you from Credit Reference Agencies, any transactional data received from your bank and building society and the information we already hold will be used for profiling and used to inform our future lending criteria.
- We will also retain information received from third parties to defend or exercise legal claims and to deal with complaints.
Additionally, we will disclose your personal information to the relevant third party:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If we are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, for example to the Financial Conduct Authority, the Information Commissioner’s Office, the Financial Ombudsman Service or HMRC.
Automated decision making
We use automated decision making as part of our loan assessment process. We use an internal scorecard which takes the data you provide us with and combines it with information from Credit Reference Agencies (this will include details on how you manage your accounts, the balances outstanding and whether your payments are made on time or not). Where you have provided consent, we may also use automated means to categorise your bank transaction data and use this in our loan assessments. From that information an automated decision is taken on whether to lend based on our pre-defined criteria. Additionally, if we do lend we would continue to run this scoring to decide whether to invite you to apply for a top up loan. The same information may also be used in automated decision making to help identify potentially fraudulent loan applications. Once you have a loan with us, we may use your account data in automated decision making to determine how to contact you for marketing and loan servicing purposes.
How long is your data stored for and how is it kept secure?
We are committed to protecting your personal and financial information. Once we’ve received your information, we use strict procedures and security features to prevent unauthorised access, alteration, disclosure or deletion.
All information kept by us is stored on our secure servers or by our trusted data processors who must comply with our security standards. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
If you become a customer, we will retain your personal data for up to 10 years after your relationship with us ends so that we can respond to any complaints. After this point, we will delete your personal data unless there is reasonable justification for retaining records for a longer period due to developments around known claims in the industry.
If you apply for a loan but do not become a customer, we will retain your name, contact information and any correspondence for up to 5 years from the date of your application in order to answer any queries you may raise, to help prevent against future fraudulent activities and to assess the performance of our decision models. We will only retain your credit reference and bank transaction data, and data used in our fraud identification process for a maximum of 90 days. After this point, we will delete your personal data unless there is reasonable justification for retaining records for a longer period due to developments around known claims in the industry.
If we received your data from a partner, such as a price comparison site, for the purposes of checking your eligibility for our products, but you did not submit an application, then we will retain your personal data for up to 90 days to inform future lending decisions. If you submit a query or complaint then we may retain any data from your correspondence with us for up to 3 years.
If we have reason to suspect fraud we will retain the necessary data to enable us to comply with anti-money laundering regulations.
Transfer of data outside the EEA
For the fulfilment of some of our services to you we transfer some data outside of the European Economic Area (“EEA”). Where we transfer data outside of the EEA we have ensured that adequate protection is in place and appropriate safeguards are applied. Please see below for more details:
- The online communications platform which we use to send our customer emails is located in the USA. 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.
- Credit Reference Agencies may share information with their head offices which are based outside of the EEA.
- Our Online Account Services provider is based outside of the EEA in the USA, however our customer information in relation to an account is hosted on servers within the EU. In the event of any incidents related to the provision of this service, the information required to resolve service issues may be shared with personnel outside of the EEA.
- Some of our fraud prevention tool providers are based in the USA. Information shared with these providers consists of your IP address, location data and device information.
- We supply information to our funders who are based in the USA. The information supplied consists of your postcode, age and transactional data.
- We outsource some administrative tasks to a wholly owned subsidiary of our Parent Company. The Company we use is BC India, they are based in India. In order to carry out administrative tasks on our behalf they have access to our systems.
We use safeguards such as Commission approved model clauses and other safeguards when transferring personal data outside the EEA. For more information or to obtain a copy of these safeguards, please contact us as set out at the end of this Policy.
What are your rights?
- The right to be informed about the processing of your personal data. This policy contains the information about how and why we process your data. If you require any additional information you can contact us using the contact details on our website.
- The right to have your personal data corrected if it is inaccurate and to have incomplete personal data completed. It’s important that the information we hold about you is correct. Please contact us at the earliest opportunity if we hold information that you believe to be inaccurate.
- The right to object to the processing of your personal data. Where we have relied on legitimate interests to process your data you have the right to ask us to stop. Where processing of the data is necessary for the performance of the contract this will not be possible.
- The right to restrict the processing of your personal data. You have the right to request the restriction or suppression of your data. This will only apply in certain circumstances. Where processing is restricted we are permitted to store the personal data but not use it.
- The right to be forgotten. You have the right to request us to delete information we hold about you. Where this is not possible we will explain why.
- The right to request access to your personal data and information about how we process it. You have the right to request a copy of the information we hold about you. You may make an access request by writing to Oakbrook Finance, The Poynt North, 45 Wollaton Street, Nottingham, NG1 5FW, contacting firstname.lastname@example.org , or calling 0208 080 6450. Any access request will be processed as required by law within one month, and will be free of charge.
- The right to move, copy or transfer your personal data (data portability) Data portability allows you to request and reuse your data for your own purposes across different services.
- Rights in relation to automated decision making including profiling. Where we have used automated decision making you have the right to request human intervention or challenge the decision.
You have the right to withdraw consent where you have previously given it, for example for the purposes of marketing communication via Email and SMS. You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to opt-out of marketing at any time by using the unsubscribe options included in the marketing communication or by updating your Marketing Preferences in your online account. Additionally, you can contact us by using our contact details on our website. If you do not give us consent to contact you via Email and SMS for marketing purposes you may miss out on special promotions or services which you may be interested in.
You would need to opt out of receiving postal marketing separately.
Should you have any issues, concerns or problems in relation to your data, or wish to notify us of data which is inaccurate, please let us know by emailing us at email@example.com. If you are not satisfied with the processing of your data you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) which is the supervisory authority for data protection in the UK. We request that you first bring any complaint to our attention prior to contacting the ICO so that we may take appropriate action to resolve the issue.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. These websites have their own Privacy Policies and we do not accept any responsibility for these sites. Please check their policies before you submit any personal data to these sites.
- Strictly necessary cookies – These are cookies that are, quite simply, strictly necessary for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our site, check your eligibility for a loan or make secure payments. If you disable these cookies, then parts of our site will no longer work for you. It also limits our ability to keep your information secure, such as when you apply for a loan.
- Performance cookies – They allow us to recognise and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. We also use third party performance cookies to record and analyse information of this nature in order for us to improve our website. Two examples are highlighted below but other cookies may be used to carry out similar functions.
- Google Analytics – We use Google Analytics to help us collect and assess this information. Google Analytics stores information such as which pages you visit, how long you are on the site, how you got here and what you click on. The information is anonymous and cannot be used to identify you. To opt out of Google Analytics cookies please visit their webpage here.
- Fospha Limited – We use Fospha for the purpose of Web Site Analytics and search engine optimisation that assist us in the improvement and optimisation of our site.
- Functionality cookies – These are used to recognise you when you return to our site. This enables us to personalise our content for you, remember your username, and remember if you are resuming an application you started previously. If you are an online account user then we’ll use a cookie to remember that and we may show you more information that is relevant to you as a result.
- Targeting cookies – These cookies record your visit to our site, the pages you have visited and the links you have followed. We will use this information to make our site and our advertising more relevant to your interests. For example, targeting cookies may help us to improve the targeting of our advertising by excluding people who have recently applied for a loan with us from seeing our adverts or by identifying audiences who are more likely to be interested in our adverts. We provide third parties such as Google and Facebook with this information so our adverts can be placed on third party websites. If you choose to block these
- Managing Your Cookies – Cookies can be controlled by your web browser settings. Whether our cookies are used will depend on your browser settings, so you are in control. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please use the following links:
- For mobile devices, you can also try looking in the browser app settings for cookie controls. Please be aware that by blocking all cookies you may not be able to access or use all the features of our website and you will not receive a personalised service.
For the purpose of the General Data Protection Regulation the data controller is Oakbrook Finance Limited and/or Oakbrook Loans Limited, as the context may require.