CLICKFUNDS.CO.UK: PRIVACY POLICY
Purpose of this Privacy Notice
At Clickfunds.co.uk, we take your privacy seriously and are committed to safeguarding your personal data. This Privacy Notice explains how we collect, process, and protect your personal data.
Contact Details
If you have any questions about this Privacy Notice, you can reach us through the following means:
Email address: contact@clickfunds.co.uk
Postal address: Triple Eight Media Ltd, 27 Old Gloucester Street, London, United Kingdom, WC1N 3AX
You have the right to file a complaint at any time with the Information Commissioner's Office (ICO), the UK's supervisory authority for data protection issues (www.ico.org.uk). However, we appreciate the chance to address your concerns first, so please contact us in the first instance.
How We Use Your Personal Data
We will only use your personal data when the law permits us to do so. The most common bases for processing your data are:
When processing your loan application details to allow you and a lender to enter a contract.
To comply with a legal obligation.
When it is necessary for our legitimate interests.
"Legitimate interests" refers to processing activities necessary for a specific purpose that we are trying to achieve, such as sending you information about a new product. However, we will only rely on this basis when it is necessary and balanced against your interests.
We have outlined in the table below the various ways we plan to use your personal data, along with the lawful basis for each processing activity, and where appropriate, the identified legitimate interests.
| Processing activity | Lawful basis |
|---|---|
| Application details to conduct a creditworthiness assessment | To work out product eligibility as a required step of entering a contract with you. |
| Incoming payments, debit card payments and funding | Necessary under the lender’s contract with you |
| Where you are a beneficial owner, director, or a guarantor, conducting personal credit, fraud, and KYC checks | For the lender to enter a contract with you and to comply with their legal obligations |
| Assisting in the application process of your loan | Necessary under the lender’s contract with you |
| Marketing our products and services to you (which you can choose to opt-out from) | For our legitimate interests in the direct marketing of our products and services |
| Credit Reference Agency checks | As a prerequisite of entering a contract with your lender |
| Fraud Prevention Agency checks | As a prerequisite of entering a contract with your lender. |
| Anti-Money Laundering checks | To fulfil the lender’s legal/regulatory obligations |
| Complaints handling | To fulfil ours and the lender’s legal/regulatory obligations |
| Arrears management (including the instruction of third parties) | Necessary under the lender’s contract with you |
| Targeted advertising service | For our legitimate interests to define types of customers for our products and services |
In some cases, we may use your data in ways not listed above, but we will inform you before doing so.
Data Collected from Third Parties
We may receive personal data about you from third parties under the following circumstances:
- Credit reference agencies provide financial standing information, credit scores, and repayment history for borrowers and guarantors.
- Additional guarantor information is provided by the main guarantor.
- Details of directors and beneficial owners are provided by the main guarantor.
- Applications referred by partners or brokers include information required for decision-making.
- Bank account transaction history is obtained when linking it as part of a credit application.
- Credit reference agencies provide financial standing information for financially associated individuals.
- Marketing data may include business names and contact details from third-party lead generators.
Credit Reference Agencies
For Clickfunds.co.uk credit facility customers, we or our partners may perform credit and identity checks through credit reference agencies (Equifax, Experian, and TransUnion).
Credit reference agencies supply both public and shared credit, financial situation, history, and fraud prevention information. This information is used to assess creditworthiness, verify data, prevent crime, manage accounts, trace, and recover debts, and provide appropriate offers.
Credit reference agencies retain your data for varying periods. If considered a fraud or money laundering risk, data can be held for up to six years. Credit reference agencies may also place search footprints on your credit file when receiving a search from us.
Fraud Prevention Agencies
To prevent fraud and money laundering, we process personal data, including name, address, date of birth, financial information, and device identifiers, for guarantors.
Data processed for fraud prevention is necessary for our legitimate interest in protecting our business and complying with applicable laws. Such processing is also a contractual requirement for the financing requested.
Fraud prevention agencies can hold your data for up to six years if you pose a risk. We may refuse to provide services or financing if fraud or money laundering risk is detected.
Sharing Your Personal Data
We may share your personal data with third-party data processors who assist in providing our services, including software platforms, telecommunications, postal services, and social media sites for market research and marketing campaigns. If your details were passed to us through a partner or broker, we may report application outcomes and loan statuses back to them.
Your data, including guarantor credit scores, may be shared within the Clickfunds.co.uk group of companies, or other third parties acting on their behalf. Additionally, we may introduce you to other lenders, and in such cases, we may share information to support your application.
International Transfers
Some data processors and hosting of personal data may be located outside the EU. When transferring data outside the EU, we ensure adequate protection through specific contracts approved by the European Commission, International Data Transfer Agreements, and Binding Corporate Rules.
Automated Decisions
We may make automated decisions regarding lending, interest rates, and terms. You have rights relating to automated decision-making, such as requesting human intervention or challenging a decision under certain circumstances.
Data Retention
We retain data for varying periods depending on the purpose and legal obligations. Generally, we or our partners, keep data for up to 7 years after the last active account or product, or after making an application. We may retain data for a longer period when necessary for legal, regulatory, or operational purposes.
Your Legal Rights
Under data protection laws, you have rights concerning your personal data. You can exercise these rights by contacting us using the provided contact details. We may need to verify your identity before fulfilling your request. We strive to respond to legitimate requests within one month, but complex cases may take longer.