This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed and used by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. Your data will only be used in a manner that is consistent with our obligations and your rights under law.
For the purpose of the General Data Protection Regulation (GDPR), the data controller is Valour Finance Limited trading as Savvy.co.uk whose registered office is at The Colony HQ, Altrincham Road, Wilmslow, SK9 4LY. Our Data Protection Registration Number is Z1012907.
We take your privacy seriously and will only use your personal information to provide you the products and services you have requested from us and to administer your account.
We receive, hold and process information relating to individuals (‘personal data’) in accordance with the GDPR. In doing so, the company is committed to maintaining the privacy and protection of all personal data collected in pursuance of its broker and loan services. As a company, we are further committed to ensuring that our website is secure in the collection and use of your personal information.
When you apply for or enquire about a loan, or our other services, we will collect personal information about you which may include the following:
To register with us you must be 18 years of age or older.
Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you or to take steps, at your request, to enter into a contractual relationship.
We will rely on your consent to share your personal information with third parties to send you marketing information about similar products and services that you may be interested in.
We will rely on the legitimate interest lawful basis to process your personal information to send you future marketing information about our products and services you may be interested in.
We collect information with a view to offering you a loan whilst satisfying regulatory requirements. We are required to confirm your identity and help to prevent fraud and money laundering.
Your information will be processed by our online decision process via savvy.co.uk and our underwriting team who will assess the information you have provided. We will either offer you a loan or tell you why we can’t.
We will use your information as follows:
With your agreement, we may wish to contact you by email, SMS, post or phone with information about other products or services which may be of interest to you. These communications may be from us or other members of The Group or it may be from other organisations offering financial products and services or from other organisations whose products or services we think may be of interest to you. We will only transfer your personal data to third parties for marketing purposes with your express consent to do so. We will notify you about the identity of the third parties in order for you to provide informed consent.
We may disclose your personal information to third parties as part of our regulatory requirements, as required by law or as you have provided consent to do so.
We may share your personal information with selected third parties including:
You are not required to provide us with viewing access to your bank account transaction information (Transaction History) or internet banking access details. You may still be allowed to apply for a loan with us if you do not provide us with this information. However, if you do it will help us make an informed decision about whether we can lend to you.
If you agree at any time that we may access your banking transaction history the following provisions shall apply:
Provide Accurate Information. You agree to provide true, accurate, current and complete information about yourself and your bank accounts (with us or third parties) and you agree to not misrepresent your identity or your account information. You agree to keep your bank account information up-to-date, accurate and complete.
Purposes. We will access your Transaction History using the services of a credit reference agency called Perfect Data Solutions Limited (PDS). We will use your Transaction History to assess your creditworthiness and whether the loan you seek is affordable.
Neither we nor PDS will store or have access to your internet banking credentials, PIN codes or passwords. That information is encrypted in transit and stored by a third party service provider upon their servers in a secure environment outside the EEA.
We ensure that any of your personal information which is stored outside the EEA is kept secure by only using service providers in the following countries (Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand, Switzerland, Uruguay and the US or, where the non-EEA service provider is not based in any of the aforementioned countries, we will enter into a written agreement with the non-EEA service provider which includes data protection clauses to obtain a contractual undertaking that your personal information will be kept secure.
Third Party Accounts. By agreeing to allow us viewing access to your Transaction History, you authorise PDS and PDS's service providers to access third party sites designated by you, on your behalf, to retrieve information requested by us, and to register to view bank statements over a period of up to 90 days. You agree that PDS and PDS's service providers may, and are instructed by you as your agent and nominated representative, with full power of substitution and re substitution, for you and in your name, place and stead, in any and all capacities, to access third party internet sites, servers or documents, retrieve information, and use your information, all as described above, with the full power and authority to do and perform each and every act and thing requisite and necessary to be done in connection with such activities, as fully to all intents and purposes as you might or could do in person. This will include the following purposes: copying Transaction History over a 90 day period and storing the copied Transaction History on our servers.
You agree that the Transaction History shall also be used by PDS for credit reference agency purposes and may be taken into account when producing your individual credit score which may be shared with other organisations as part of your credit record.
You acknowledge and agree that when we, PDS or PDS's service providers access and retrieve information and Transaction History from third party sites, this is undertaken as your agent, and not the agent on behalf of any third party (including the bank account provider). You should be aware that third party account providers shall be entitled to rely on this authorisation and agency granted by you. You should also be aware that this service is not endorsed or sponsored by any third party bank account providers. We would recommend that you refer to the terms and conditions of your internet banking provider if you would like more information.
You understand that allowing us to review your Transaction History is at your sole risk. We are only able to review your Transaction History on an "as is" and "as available basis" as it is made available to us by service providers. It may not be available to us from time to time. We cannot guarantee that allowing us to review your Transaction History will guarantee the success of your loan application or the rate at which the loan is available.
It is your responsibility to review and check your declared expenditure item values to ensure that they are accurate, correct and specific to your financial circumstances.
We rely on the information submitted on the income and expenditure form, to assess that the loan amount requested and the associated repayments are affordable for you, based on our lending criteria.
It is important that all information which you provide us with during the application process is accurate, honest and correct. We take no responsibility for lending to you based on you having provided us with false, incorrect or fraudulent information. You also agree that by making the application with us that you are not currently experiencing financial difficulty and are not in the process of entering, or currently on a debt management plan, IVA, bankruptcy proceedings, or any other debt help solution.
When you apply for a loan you confirm that all the information you have given is true and complete.
We will make such checks when assessing your application.
When CRAs receive a search from us they will place a search “footprint” on your credit file that may be seen by other lenders. They supply to us both public (including the electoral register) and shared credit and fraud prevention information. Large numbers of applications within a short time period may affect your ability to obtain credit, this is applicable whether you have been accepted or declined.
If you tell us that you have a spouse or financial associate, we will link your records together so you must be sure that you have their agreement to disclose information about them. CRAs also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.
Information on applications will be sent to CRAs and will be recorded by them. Where you borrow from us, we will give details of your accounts and how you manage it / them to CRAs. 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 and FPAs to perform similar checks and to trace your whereabouts and recover debts that you owe. This may affect your ability to obtain credit in the future.
Credit records remain on your credit file for a period of 6 years after which date they are closed, whether settled by you or following a default.
If you provide us with false or inaccurate information or we identify fraud, details may be passed to FPAs and other organisations involved in crime and fraud prevention including law enforcement agencies who may then access this information
We and other organisations may also access and use this information to prevent fraud and money laundering, CRAs and FPAs may use your information for statistical analysis. Information held by CRAs and FPAs will be disclosed to us and to other organisations in order to, for example, when:
We and other organisations may access and use, from other countries the information recorded by fraud prevention agencies.
Your data may also be used for other purposes for which you give your specific permission or, in very limited circumstances, when required by law or where permitted under the terms of the GDPR.
The three main Credit Reference Agencies, Call Credit, Equifax and Experian will use and share your data in line with the Credit Reference Agency Information Notice (CRAIN) for further information on how CRA’s use your data please visit their websites as stated below.
Should you wish to obtain a copy of the personal data other agencies hold about you please write to:
CallCredit Limited , One Park Lane, Leeds, LS3 1EP
Equifax Limited, Customer Service Centre, PO Box 10036, Leicester, LE3 4FS
Experian Limited, PO Box 9000, Nottingham, NG80 7WF
The Fraud Prevention Agency that we use is Action Fraud - www.actionfraud.police.uk
If you wish to see the information contained on a credit reference agency file you can do so by writing to the relevant agency. The agency must respond within one month. If your credit reference file contains information about other people with whom you have no financial connection or if it contains information which is incorrect you can ask for the entry to be corrected, removed, or have a note put on the file explaining why you think the information is wrong. The agency will not remove correct information.
The Information Commissioner’s Office provides a useful leaflet which explains how to request changes to your credit reference file. The easy to read leaflet includes examples of letters and details of various actions you may take to amend a file.
Information is available at https://ico.org.uk/media/for-the-public/documents/1282/credit-explained-dp-guidance.pdf.
Credit reference agencies keep a wide range of information. This includes information from the electoral roll (sometimes known as the voters’ roll) and records of most county court judgements and bankruptcies. They also retain information relating to previous and existing credit and a record of searches made against the file. The lenders share information through the agencies providing a history of how punctually payments are being made or have been made. Loan information is usually held on file for 6 years once settled. Details of the Electoral roll may be held for much longer. Information about credit searches is kept for 12 months.
Reports from CIFAS relating to fraud and fraud avoidance are also available to most lenders – these contain information indicating that fraud, or attempted fraud, has been notified by a lender. The information might not directly relate to you, it might relate to someone who has tried to impersonate you. Data available to members of CIFAS may also be used to help make decisions on motor, household, credit, life and other insurance proposals for you and members of your household. CIFAS information is intended to warn lenders and act as a protection for innocent customers.
The Council of Mortgage Lenders, Repossession Register is available through the main credit reference agencies. If you have had a property repossessed or have given it up voluntarily this will show on the register.
A file may also show a “gone away” marker indicating that a member of the “Gone Away Information Network” has reported that they cannot trace a customer who is in arrears with payments. Alternatively, the marker may indicate a new address which the “gone away” has been traced to.
Files in this register contain detailed information on applications made and loans given. It is aimed at tracing fraudsters who use different combinations of information to obtain credit dishonestly. It checks and counter checks information given on application forms.
If we use any of the above agencies they will be able to confirm their contact addresses.
Your information is stored electronically within our servers and case management systems. Some of your information is segregated to reduce risk, access is controlled and our systems are backed up regularly to ensure integrity. Any payment transactions will be encrypted using SSL technology.
Where we have given a password PIN code 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.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
How long we keep your information for depends on the basis on which it was provided. Generally, however, we will keep the information that is necessary to enable us to provide you with a service that you have requested for as long as it takes us to provide that service. If you have asked that we do not use your details for marketing purposes, we may still need to keep them to ensure our systems reflect your preferences. In these circumstances we will only retain minimum information to enable us to honour your suppression request.
We will generally keep records of any transactions you enter into for a minimum of six years from the end of the relationship. This is so that we can respond to any complaints or disputes that arise in that period. Otherwise we will keep the information where appropriate for legitimate business needs, namely future marketing of products and services which may interest you. We will always give you the option to opt-out of receiving any future marketing communication within each communication.
We will keep other information about you if it is necessary for us to do so to comply with the law, regulations, or where appropriate for legitimate business needs, namely marketing. For any marketing purposes for which you consented to, we shall keep your information no longer than it is necessary to comply with this objective, namely until you notify us of a change in your marketing preference.
If you wish to find out how long your information is held for with the third parties we share your information with, their contact details are provided under how to find out more within this notice.
You can see what information we hold about you by asking us for a copy at any time. We will also tell you where the information was obtained from. You will need to put your request in writing and we will respond within one calendar month, there is no fee chargeable for this request.
Should you wish to obtain a copy of the personal data we hold on you please write to the relevant company at the address shown below. As soon as we are satisfied as to your identity we will send you, and within the legislated time, depending on the date of your request, a copy of all the data we hold concerning you.
You have the right to obtain human intervention, to express your point of view and to contest a decision which we make on an automated basis.
You have the right to ask us not to process your personal data for marketing purposes. If you do not want us to use your personal data to contact you by electronic means (email or SMS) with information about other products offered by any company within the Valour Group (UK) Plc, or other third parties you can revoke your consent by opting out please contact us at [email protected] or call 0330 002 0118.
Important information about our loans. Please take time to read about us and how we operate as we take our responsibilities and duties as a provider of consumer finance seriously.
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