Fairlo

Privacy Notice

Fairlo’s approach to personal data

Last Updated: 21 February 2022

Fairlo takes protecting your personal privacy very seriously, and for us it is important that you feel safe when contacting us, taking credit through us or otherwise letting us process your personal data.

In this policy, we describe:

  • Why we need to process your personal data when you contact us, apply for credit or enter into a credit agreement with us
  • How we process your personal data
  • What rights you have
  • How you can get in touch with us if you have any questions

1. Who we are

We are Fairlo UK Limited with company number 13566128 and address Wisteria Grange Barn, Pikes End, Pinner, Middlesex, United Kingdom, HA5 2EX and is registered with the Information Commissioner’s Office (Registration No. ZB258571). We are responsible for the personal data Fairlo processes about you.

You can contact us at any time at privacy@fairlo.co.uk if you want to know more about how we process your personal data. You can also read more about us on our website www.fairlo.co.uk.

2. Why we need your personal data

Personal data means any information which relates to an individual and can be used for the purposes of identification, either directly or indirectly, typically through the use of an identifier.

Our starting point is to only process the personal data required for us to be able to assess your credit application and fulfill our obligations under the credit agreement. We also need to process your personal data in order to meet legal requirements, such as complying with the Financial Conduct Authority's and ICO’s regulations.

We also process your personal data for marketing, customer analysis, product development, and to make your customer experience as good as possible.

3. What and how do we collect your personal data

We collect, process and use the following personal data when you contact us, apply for credit, enter into an agreement with us and as part of our ongoing relationship.

  • Identity - first name, last name, date of birth.
  • Contact Details - address, email, mobile number.
  • Financial Information - your income and outgoings including the number of dependents, employment status, preferred repayment date and credit history.
  • Banking Details - your bank account number and sort code.
  • Usage Information - about how you have used the website, your Fairlo online account and communications with Fairlo. This includes things like date and time, time on a page, navigation between pages, page interaction and other similar information.
  • Device Information - about what device you have used to access the website, your Fairlo online account and communications with Fairlo. This includes things like device type, operating system, browser type, the Internet Protocol (IP) address.

These are collected from a variety of sources:

  • Information you give us
  • Information we receive from third parties, including third parties who provide services to us (for example credit reference agencies or fraud prevention agencies)
  • Information we learn about you through our relationship with you and the way you operate your products
  • Information that we gather from the technology which you use to access our services
  • Information gathered through website cookies

More information about what information is shared with credit reference agencies can be found in section 7.1.

4. How we process your personal data

Data protection law says that we can only use personal data if we have a proper reason to do so. For example, these reasons include fulfilling a contract we have with you, when we have a legal duty, when it is in our legitimate interest or when you consent to its use. When data protection law allows us to process your personal data for our own legitimate interests, it is only allowed provided those interests do not override your own interests and/ or your fundamental rights and freedoms.

An example of where we would process your personal data for our legitimate interests would be where you believe you are the victim of fraud and in order to investigate your claim we may have to share your name and account number, payment and other details of the case with any other bank involved. Sharing personal data in these circumstances would not only be in our legitimate interest but also yours. An example of us using your personal data when we have a legal duty, is where we must do so in order to comply with anti-money laundering obligations.

Our purposes for processing your personal data are grouped under our four legal bases for processing below.

A contractual obligation basis

  • To consider and process applications made for products and services we provide, which may involve sharing information with credit reference agencies and fraud prevention agencies, or by other means, such as assessing information we hold about you, for instance, where we have an existing relationship with you.
  • To deliver the products and services we provide, including:
    • Transferring withdrawals to your nominated account
    • Receiving repayments from your nominated account
    • Providing you with information and guidance on the products and services you hold
    • Providing statements, reminders and notices informing you of forthcoming changes, such as increasing or decreasing credit limits
    • Calculating the interest which may apply to your account
    • To address enquiries or complaints we may receive from you or a representative appointed by you
    • Assisting you with managing the products and services you hold

A legal obligation basis

  • Confirm your identity
  • Perform checks to detect and prevent financial crime
  • Share data with credit reference agencies and fraud prevention agencies
  • Comply with legal and regulatory requirements
  • Where we have a duty to protect vulnerable customers

A legitimate interest basis

  • Understanding how our customers use our products and services, so we can improve these
  • Developing new products and services and identifying which may be of interest to you
  • Sharing information with organisations who introduce you to us under a commercial agreement – for instance, where we pay them commission
  • Improving our systems and processes, which may include using your personal data to test the accuracy of these, but only where it is essential to do so
  • To recover money owed to us
  • To invite you to participate in market research and customer surveys;
  • To sell to, or purchase debts from other firms
  • Sharing your personal data with any person to whom we may transfer, or may consider transferring any of our rights or business
  • To share information with third parties for the purpose of preventing fraud and financial crime
  • Identifying and managing risks to our business

A consent basis

Where we have the relevant permissions: contacting you to make you aware of these products and services, including sharing information with third parties who may add to this information they know about you and use this to deliver such messages to you on our behalf via social media – note: we may contact you for a reasonable period after you cease your relationship with us.

Marketing

We may use your personal data to tell you about relevant products and offers that we think you may find interesting. We can only use your personal data to send you marketing messages if you have given your consent or it is for a legitimate interest (when we have a business or commercial reason to use your information).

You can ask us to stop sending you marketing messages by contacting us at any time, although you will still receive important information, and communications of any changes, to your existing products and services.

You can change your mind and update your choices at any time by using the “unsubscribe” or “opt out” option in any marketing communication you receive from us or by contacting us at privacy@fairlo.co.uk.

5. How long we keep your personal data

We will retain your personal data for as long as we are obliged, under relevant legislation and regulation, or where no such rules apply, for no longer than it is necessary for our lawful purposes. We will keep your personal data as long as you are our customer, even though we will anonymise or erase personal data we no longer need on an ongoing basis. After you are no longer a customer with us, we will usually not keep your personal data for more than seven years from the point at which the obligation to retain a record containing your personal data begins. The retention period of your personal data may need to be extended where we require this to bring or defend legal claims. We may also retain data for longer periods for statistical purposes, and if so we will anonymise your personally identifiable data.

If you have given your consent to marketing, we will process your personal data for that purpose as long as we have your consent to it. You can at any time request that we stop processing your personal data for this purpose.

6. How we protect your personal data

Your safety is important to us. We have therefore taken appropriate technical, organizational and administrative security measures to protect your personal data from unauthorized access and other unauthorized processing. Our IT systems are compatible with the requirements of the GDPR and other applicable data protection legislation.

7. Sharing your personal data with third parties

We do not disclose your information to other companies unless required by law or required for you to apply for credit or enter into a credit agreement with us. We might also disclose your information when we have a legitimate interest to do so.

If you apply for credit, we need to disclose your personal information to our partners who perform the credit assessment and credit assessment required for you to be granted credit by us. We also need to provide your personal information so that the credit you have been granted can be transferred to your bank account.

When required by law or other regulations, we may need to disclose your information to authorities and other organizations. We may also need to disclose your information if it is necessary to exercise, establish or monitor our legal claims.

We do not disclose your personal information to other companies or organizations for their marketing purposes, unless we have obtained your consent to do so.

Credit Reference Agencies

In order to process your application we will supply your personal information to credit reference agencies (CRAs) and they will give us information about you, such as about your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity.

We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations. Your data will also be linked to the data of your spouse, any joint applicants or other financial associates.

The identities of the CRAs, and the ways in which they use and share Personal Data, are explained in more detail at https://www.experian.co.uk/legal/crain/ and https://www.transunion.co.uk/legal/privacy-centre?#pc-credit-reference.

Types of third parties we may share data with

  • Communications providers e.g. mail, email and SMS services
  • Credit Reference Agencies
  • Fraud Prevention Services
  • Debt Collection Agencies
  • IT Consultants
  • IT service providers
  • Legal Services
  • Market Research
  • Marketing service providers
  • Payment Processors
  • Software Providers
  • Web Analytics service providers
  • Website Hosting service providers

8. Your rights

When we process personal data about you, you have several rights under the data protection legislation. You have the right to contact us at any time regarding these, and if you want to exercise any of the rights described below, you can reach us at privacy@fairlo.co.uk.

We reserve the right to take appropriate protective and safety measures in order to ensure that you are who you claim to be when you contact us. If you are unable to prove your identity in a credible manner, we may not be able to accommodate your request.

The right to be informed

You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. We fulfil this right by giving you this notice.

The right of access

You have the right to know which personal data we process about you. If you want to know, you can get a compiled register extract from us that contains the personal data we process about you.

The right to to rectification

You can ask us to change or complete any inaccurate or incomplete personal data held about you.

The right to erasure

This is also known as “the right to be forgotten” and this means that you can ask us to delete your personal data where it is no longer necessary for us to use it, you have withdrawn consent (where applicable), or where we have no lawful basis for keeping it or otherwise using it. There are limited exceptions, for example where we need to use the information to bring or defend a legal claim.

The right to data portability

In certain circumstances, you have the right to receive the information we process about you in a general, written, machine-readable and structured format. You have the right to do so with regard to the personal data that you have provided to us and that we process with the support of your consent or when the personal data is required to enter into or fulfill an agreement with you.

The right to restrict processing

Under certain conditions, you have the right to request that we limit our processing of your data. This means that we mark the data so that in the future we only process them for certain specific purposes. We may not offer you credit if we restrict the processing of your personal data.

The right to object

You have the right to object to the processing of personal data that is performed for the purpose of performing a task of general interest, as part of the exercise of authority or in our legitimate interest. We process some of your personal data on the basis of our legitimate interest, and you have the right to object to such processing.

Rights in relation to automated decision making and profiling

We use automated decisioning when we assess whether your application for credit can be granted, assessing your account behaviour and determining the appropriate action to take, where your account has gone into arrears or default.

This means that our decision is made automatically without any human intervention. We do this to make decisions more consistent, fair and quicker. You have the right not to be subject to a decision based on solely automated processing, including profiling, if this will have a legal or other significant effect on you (unless certain exceptions apply).

We will use your personal data in profiling in order to identify your suitability for products and services we offer and to inform you of these. Where an individual’s financial history suggests they are unlikely to be accepted for a particular product or service, we may use that data to opt them out of receiving information about that product or service. This is in individuals’ interests as it helps stop them receiving irrelevant marketing or being targeted with marketing about products that they cannot afford. These types of profiling are only used in relation to our own products and services and as such are generally not considered to have a significant effect on your rights and interests.

Right to lodge a complaint

You also have the right to complain to the Information Commissioner’s Office. You can call their helpline on 0303 123 1113, or you can visit their website (www.ico.org.uk) for information on how to make a data protection complaint.

9. Fairlo's approach to cookies

To make our site work properly, we sometimes send small files to your computer. These files are called cookies. Most websites do the same thing to improve your experience.

10. What are cookies?

Cookies are small text files that are saved on your computer, phone or tablet when you visit websites. The cookies help the website remember your settings (e.g. username, language, text size and other preferences) for a certain period of time. The idea is that you should not have to redo the settings every time you enter the website or browse between different pages. The cookies can also be used to save information about how you use the site, which can help customise your site experience.

11. How we use cookies

Fairlo uses cookies from third parties. These are mainly used to:

  • Analyze website behavior to improve the website and its user experience
  • Build segments for advertising
  • Show relevant ads to previous visitors
  • Minimize advertising to visitors where it is not relevant
  • Test different content on the website

12. How you can control the cookies

You can control and delete cookies exactly as you want, whenever you want. You can even delete all cookies on your computer and you can set your browser so that it does not receive or send any cookies. However if you did that, you may need to reset certain settings each time you access a website and some services and features may not work. Read more about how to handle cookies in general at https://allaboutcookies.org/how-to-manage-cookies

Do you have more questions?

Get in touch with us, we will be happy to help.

Contact us