Privacy Policy

(last updated 23/06/2022)

About this policy

This policy provides an overview of how Fair for You Enterprise CIC (“we”) will process any personal information we collect about you and how we will comply with data protection legislation and protect the rights of the individuals we deal with.

It sets out below:

  1. Who we are and who is responsible for your personal data and general information;
  2. What information we collect about you;
  3. How we use your information;
  4. What credit reference and fraud prevention agencies do with your information;
  5. How your data will not be used by credit reference agencies and how to contact them;
  6. How we safeguard your information and how long we keep it for;
  7. Marketing & Cookies
  8. Where we transfer your information;
  9. With whom we share personal information, and why;
  10. Your rights;
  11. Open Banking
  12. Changes; and
  13. How to find out more.
  1. Who We Are And Who Is Responsible For Your Personal Data and General Information
    1. Fair for You is the Trading Name of Fair For You Enterprise Community Interest Company – Company Number 09798014. Authorised and Regulated by the Financial Conduct Authority FRN 719715. Members of the Financial Ombudsman Scheme. Fair For You Enterprise Community Interest Company is wholly owned by Fair For You Limited of Unit 8, Elm Court, Meriden Business Park, Copse Drive, Coventry, CV5 9RG. Registered in England and Wales Number 8991099. Fair For You Limited is a registered Charity Number 1161809.
    2. Fair for You is responsible for your personal data and will ensure that it is handled in accordance with The General Data Protection Regulation (GDPR) which, together with the Data Protection Act 2018 (DPA 2018), forms the data protection regime in the UK.
    3. If you have any queries or concerns regarding this Privacy Policy or how we handle your personal information, please contact us at:
      1. Email Address: [email protected]
      2. Postal Address: Unit 8, Elm Court, Meriden Business Park, Copse Drive, Coventry, CV5 9RG
  2. What information we collect about you
    1. We may collect and process the following data about you (‘your information’):
      1. information that you submit online via our Site or over the telephone including (but not limited to) when you apply for a loan or register an interest with us;
      2. any correspondence you send to us which might include, for example, proofs of ID, proofs of address and bank statements;
      3. copies of any agreements you enter into with us;
      4. details of transactions you carry out or orders you place through the Site (or over the telephone); and
      5. details of your visits to our site and the resources that you access (which may include, amongst other things; traffic data and communication data).
    2. To enable us to meet our obligation to check the identity of our customers (new and existing) we may also collect your information from third parties, including our finance partners, credit reference agencies and fraud prevention agencies to make a decision about whether we can offer you a loan and the products and services we/our partners can offer you.
    3. In order for us to process your loan application and in order to comply with money laundering regulations, before we provide any service, as mentioned above, we may search the records of one or more registered credit reference agencies (either directly or via one of our banking partners) who will provide us with information from the electoral register and any other data appropriate to the search. The agency will keep a record of that search. This may be used by other lenders when processing future applications for credit you may make. We will also search at fraud prevention agencies for information held about you and any addresses at which you have lived for information about you or any business you have (if you have one).
    4. Information held about you by the credit reference agencies may already be linked to records relating to your partner/spouse. Where appropriate, any loan applications submitted may be treated as financially linked and your application may be assessed with reference to any ‘associated’ records and accordingly we will collect the information about you and the “associated” records.
    5. If your loan application is successful, your details will be held by us to enable your loan to be managed.
    6. We are regulated by the regulator of community interest companies. Information on how we are regulated can be found at their website here https://www.gov.uk/government/organisations/office-of-the-regulator-of-community-interest-companies.
    7. We are aware that your information may be confidential and we will protect the confidentiality of your information in accordance with our normal procedures and legal requirements.
  3. How we use your information
    1. We use your information in the following ways:
      1. To progress your loan application;
      2. to ensure that the Site’s content is presented as effectively as possible for you, including the pre-filling of forms using the information we already hold about you;
      3. for our internal purposes, such as quality control, site performance, system administration and to evaluate use of the Site, so that we can provide you with enhanced services;
      4. If you give us false or inaccurate information and we suspect or identify fraud we will record this and may also pass this information to fraud prevention agencies and other organisations involved in crime and fraud prevention.
    2. Unless otherwise indicated, we process your information in these ways for the performance of, or to take steps to enter into, a contract with us for the provision of credit and for legitimate business purposes.
    3. We will not sell your details to any third parties. However, we may share your information with people who are authorised to act on our behalf, for example in address validation. We will also share your details with third parties where obligated to do so by law.
    4. In the event that you default on your loan or any terms and conditions in relation thereto, details of such default or defaults will be passed to other lenders, debt recovery agencies and courts. In such circumstances, it is understood that the lender may disclose details of the borrower’s account and any matters relating to the account to any credit reference agency and to any individual, individuals or organisations for this purpose registered by the lender with the data protection registrar.
    5. We will use the information we receive from credit reference agencies to:-
      1. Assess your application for a loan;
      2. check details on applications for credit/loan and credit/loan related or other facilities;
      3. verify your identity;
      4. undertake checks for the prevention and detection of crime, fraud and/or money laundering;
      5. manage your personal account (if you have one) with us; and
      6. undertake periodic statistical analysis or testing to ensure the accuracy of existing and future products and services.
    6. We may use scoring methods to assess your application and to verify your identity.
    7. We may use your information in case studies that we produce which will then be used for advertising and marketing purposes. We will obtain your consent to do this.
    8. We may further use your information to:
      1. notify you about changes to our services;
      2. provide you with information, products or services that you request from us, or which we feel may interest you (provided of course that you have agreed);
      3. create reports to assist with future marketing;
      4. complaint handling purposes;
      5. carry out our obligations arising from any contracts and loans with you or under the law and for billing and delivery purposes;
      6. enable you to participate in the features of the Site, when you choose to do so; and
      7. help us improve our products and services.
    9. We use automated decisions with regards to your loan application to us. The purpose of this is to speed up the process, and generate a credit score profile to assess if you are capable of repaying the loan amounts. Should you wish for an automated decision to be manually checked or object to this processing as part of the contract please email [email protected] with information about your loan application.
    10. We may monitor your use of the Site and record your email address and/or IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical information about our users’ browsing actions and patterns and does not identify any individual.
    11. We collect non-personal aggregated statistics data about visitors to the Site in a given time period and sales and traffic patterns. Just to be clear, this information does not identify users in any personal capacity, nor is any personal data used to build this information. It contains generalised information/totals about the users of the Site, for example how many users visited the site, how many users clicked through to loans.
    12. We use Credit Profiling/scoring to process you loan application promptly, this is part of the contract. The logic of the score a combination of weighted know credit factors including: income, type of home ownership, financial commitments, benefits, payment history, and other financial data about you, to create a credit profile about you and if you are capable of repaying the loan amounts.
  4. What Credit Reference and Fraud Prevention Agencies do with your information
    1. Any credit reference check we carry out will:
      1. Place a search “footprint” on your credit file whether or not this application proceeds. If the search was for a loan application the record of that search (but not the name of the organisation that carried it out) may be seen by other organisations when you apply for credit in the future;
    2. The credit reference agency will supply to us:-
      1. credit information such as previous applications and the conduct of the accounts in your name and any of your joint applicants;
      2. public information such as County Court Judgments (CCJs) and bankruptcies;
      3. electoral Register information; and
      4. fraud prevention information.
    3. If you borrow and do not repay in full and on time, credit reference agencies will record the outstanding debt.
    4. Records shared with credit reference agencies remain on file for 6 years after they are closed, whether settled by you or defaulted.
    5. If your application is successful, details of how you repay this agreement may be provided to the credit reference agency who will make this available to other lenders who may use the information for credit assessment, tracing of absconders and fraud prevention.
    6. If you give us false or inaccurate information and we suspect or identify fraud we will record this and may also pass this information to fraud prevention agencies and other organisations involved in crime and fraud prevention
    7. The information which we provide to the fraud prevention agencies about you, your financial associates and your business (if you have one) may be supplied by fraud prevention agencies to other organisations and used by them and us to:
      1. prevent crime, fraud and money laundering;
      2. manage your personal, your spouse’s or other joint applicant’s credit or credit related account or other facilities;
      3. check details provided on applications for credit and credit related or other facilities;
      4. manage credit and credit related accounts or facilities;
      5. cross checking details provided on proposals and claims for all types of insurance;
      6. make decisions on credit and credit related services about you, your spouse, other joint applicant(s) and/or other members of your household; and
      7. check details on applications for jobs or when checked as part of employment.
    8. Your information may also be used to:-
      1. verify your identity if you, your spouse, other joint applicant(s) applies for other facilities;
      2. trace your whereabouts and recover debts that you owe;
      3. conduct other checks to prevent or detect fraud;
      4. undertake statistical analysis and system testing; and
      5. we and other organisations may access and use from other countries the information recorded by fraud prevention agencies.
    9. The Identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at https://www.transunion.co.uk/crain
    10. Please contact us at [email protected] for details of the relevant fraud prevention agencies.
  5. How your data will NOT be used by credit reference agencies and how to contact them:-
    1. It will not be used to create a blacklist.
    2. It will not be used by the credit reference agency to make a decision.
    3. You can contact the Credit Reference Agencies currently operating in the UK; the information they hold may not be the same so it is worth contacting them all. They may charge you a small statutory fee.
  6. How We Safeguard your Information and how long we keep it for
    1. The following ‘Retention Periods’ are applicable for all loan applicants:
      1. successful Loan Applicant details: a maximum period of six years after you have fulfilled all loan payment obligations;
      2. unsuccessful Loan Applicant details: a maximum of six years after loan application rejection.
    2. We will use your information only for specific legitimate purposes. We will keep information about you that is necessary for us to provide you with a service or product you have requested.
    3. We will keep personal information secure by taking appropriate technical and security measures to protect it against the unauthorised or unlawful processing and against accidental loss, destruction or damage.
  7. Marketing & Cookies
    1. We may use your information to provide you with marketing information (including information from third parties) that you request or that we feel may interest you by post, email and/or telephone (including SMS).
    2. If you are an existing customer, or have not made a purchase but have taken steps to do so by using the Site or contacting us, we may contact you by email/SMS/telephone/post with information about products and services which are similar to those we previously provided to you, unless, at the time we collect your contact information, you have indicated that you do not want to receive marketing information.
    3. We may also work with third party advertisers and platforms (such as Facebook and Google) to advertise our services to the most relevant audiences. This can involve the provision of protected ID data (for example, an email address which is converted into a stream of numbers or letters (hashed) to help make it more secure) to match the data we hold about you with the data they hold on their platform and provide you with relevant advertising (subject to your ad permissions on the relevant platform).
    4. We process your information in this way for legitimate business purposes, and in doing so we ensure that we always keep your Personal Data in high regard and take account of these rights.
    5. If you do not want us to use your information for marketing purposes, please indicate your preference via the relevant boxes on any of the forms you submit when providing your contact information. You may also ask us at any time not to use your information for marketing purposes by contacting us via the following methods:
      1. Email: [email protected]
      2. Phone: 03334330739
      3. Post: Fair for You, Unit 8, Elm Court, Meriden Business Park, Copse Drive, Coventry, CV5 9RG
    6. When you visit our site we may collect personal data from you automatically using cookies or similar technologies. A cookie is a small file that can be placed on your device that allows us to recognise and remember you.
    7. This policy includes our cookie policy, where you can find details of our key advertising partners.
  8. Where we transfer your information
    1. We will not routinely transfer your information to, or store it, outside of European Economic Area (‘EEA’). If we do wish to transfer your personal data outside the EEA to countries which do not have as developed data protection laws, we will ensure that it is adequately protected in accordance with Principle 8 of the DPA.
    2. Please do not send us your information if you do not want it to be transferred to or stored outside the EEA. By providing your information to us you agree and consent to us transferring to, and storing your information at a destination outside the EEA.
  9. With whom we share your information, and why
    1. We may share your information with other organisations:
      1. if we sell or buy any business or assets (as we may share your data with the prospective seller or buyer);
      2. if we or substantially all of our company assets are acquired by another party, in which case your information will be one of the transferred assets;
      3. with service providers, business partners, suppliers, sub-contractors for the performance of any contract we enter with them or you; and
      4. if we have to share your information to comply with legal or regulatory requirements, or if we have to enforce or apply our loan agreements, Terms or any other agreements or to protect our rights, property or our customers. This may involve exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
    2. We may share the non-personal aggregated statistics data about Visitors to the Site with third parties.
    3. We may also share your information with selected third parties for the purposes of credit reference, order fulfilment, delivery, data analysis, customer support and other services.
  10. Your rights
    1. You can access and rectify certain parts of your personal information by logging into your account.
    2. Under the Data Protection Act 1998 you have the right to see the personal information that we hold about you (with the exception of the assessment of your application) in most cases this information will be provided free of charge, however we may charge a reasonable fee to cover our administrative costs if the request is manifestly unfounded or excessive, particularly if it is repetitive. Before we agree to this, you must provide us with sufficient evidence of your identity and sufficient details of the information you wish to see to enable us to locate it. To request a copy of your information please contact us via email [email protected] or post.
    3. You have the right to correct any errors in information we hold about you, to change or correct any details you have already given us or in some instances erase data that we hold about you. Please inform us about changes to your details so that we can keep our records accurate and up to date.
    4. You have the right to ask us not to process your information (or pass your information to other companies or organisations) for marketing purposes and be removed from our mailing lists, and those of our partner organisations. Instructions on how to stop further mailings will usually be contained in any direct marketing material we send out. Otherwise please contact us via email [email protected] or post.
    5. You have the right to ask for information we hold about you to be reused for other purposes across different services.
    6. We will respond to your request within one month upon receipt.
    7. If you have a complaint about how we have used your information, you have the right to complain to the Information Commissioner’s Office: https://ico.org.uk/global/contact-us/
  11. Open Banking
    1. This section of our Privacy Policy relates to Open Banking and should be read in conjunction with the other clauses in our Privacy Policy. In the event of conflict with any other clauses, this clause shall prevail.
    2. What is Open Banking? Open Banking is the secure way of providing access to your bank or building society account to providers who are registered for this purpose. Registered providers and participating banks and building societies are listed under the Open Banking Directory. Open Banking was set up by the UK Government to encourage more competition and innovation in the financial services sector.
    3. As a forward thinking lender, we support the use of Open Banking as it allows us to process loan applications efficiently, securely and in our consumer’s best interests.
    4. By permitting access to your bank or building society account information we are able to make a better lending decision as we shall be able to verify your income, outgoings and other matters in order to assess what loan terms would be suitable for you based upon what you can reasonably afford to repay.
    5. Further information about Open Banking is available from www.openbanking.org.uk.
    6. How will my personal data be shared and used for the purposes of Open Banking? By proceeding with your loan application via our website you expressly consent to us sharing your personal, contact and loan application details (“the Shared Personal Data”) with our registered Open Banking partner, Perfect Data Solutions Limited (“PDS”) who are also a credit reference agency. During your loan application we shall safely and securely direct you to PDS’s secure portal (“the Portal”) for the purposes of granting PDS access to your bank or building society account information (“Transaction Information”). As soon as your Transaction Information is received it shall be reported back to us in the form of a completed search in order that we may continue to process your loan application (“the Permitted Purpose”). Further information about PDS including their registered provider and regulatory status is available from www.lendingmetrics.com.
    7. Is Open Banking secure? PDS are registered under the Open Banking Directory as an account information service provider and are also regulated by the Financial Conduct Authority as a payment services firm under number 802599. Any data you submit via the Portal will be encrypted and its usage tracked as part of set Open Banking data security standards. We are responsible for the secure transmission of any Shared Personal Data to PDS, for safely directing you to the Portal and for the safe receipt and usage of your Transaction Information. You will not be required to share your banking password or log in details with either us or PDS. Once you have given your explicit consent to share your bank account information on the Portal you will be directed to your own bank or building society’s login page where you will enter in your own login details directly.
    8. Save as set out above or elsewhere in this Privacy Policy, we are not responsible for your direct data transmissions with PDS or with your own bank or building society.
    9. How will my Shared Personal Data and Transaction Information be used? PDS shall, subject to their own terms and conditions and privacy policy, and, if your bank or building society is registered to provide access under the Open Banking Directory, obtain your Transaction Information and submit this back to us for the Permitted Purpose. By way of example, the Transaction Information that we shall receive is likely to include information relating to your income, outgoings and credit worthiness.
    10. PDS shall be entitled to re-access your Transaction Information for up to 90 days from the date of your original search result in order to refresh the search results, obtain a snapshot of your data or gather additional data.
    11. PDS shall hold the Shared Personal Data and the Transaction Information they receive and retain according to their own terms and conditions and privacy policy, available on the Portal, which you will be required to read and consent to once directed their via our website.
    12. As PDS are also a credit reference agency they may also share and keep a record of your Shared Personal Data and Transaction Information.
    13. Will you use my Transaction Information data for any other purpose? The Transaction Information we receive about you will only be used for the Permitted Purpose. We do not sell or share Transaction Information with any third party.
    14. Save as set out above the information contained in the rest of this Privacy Policy deals with how we collate, use, transfer, store, delete and other terms applicable to your personal data including Shared Personal Data and Transaction Information.
    15. Do I have to provide you with my consent to proceed? Consent must be provided to allow for us to assess your bank statements digitally. If you would prefer not to give your consent for this and we need Bank Statements to review your application, you can also provide them by sending Screenshots/Pictures to us as described in the email we will send you.
    16. Where your bank or building society have already permitted access to your Transaction Information you shall need to contact them directly in order to withdraw your consent under their particular Open Banking terms and conditions.
    17. Are any of my other rights under this Privacy Policy affected? Your individual data protection and privacy rights including the right to access, correct, delete, object, restrict, withdraw consent, request transfer and/or make a complaint, continue to apply to relevant personal data we control or process and are dealt with elsewhere in this Privacy Policy.
    18. Under Open Banking as your personal data is shared by your bank or building society and accessed by PDS you may also be able to exercise your individual data protection and privacy rights against either of them pursuant to their own terms and conditions and privacy policies.
  12. Changes
    1. We may make changes to this Policy at any time by sending you an e-mail with the modified Terms or by posting a copy of them on the Site. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on the Site, whichever is the earlier. Your continued use of the Site after that period expires means that you agree to be bound by the modified policy.
  13. How to find out more
    1. If you would like any further information on how we use your information, please contact us by calling 0333 433 0739 or email us at [email protected].