Last updated July 2021
At Loans 2 Go, we always respect the privacy of our customers and are committed to protecting your privacy at all times. This policy will give you a thorough explanation of the way we collect your data and how it may be used. It may be updated from time to time so you should review it occasionally.
How we collect your personal information
Your information will be collected and processed by Loans 2 Go during the use of our websites or when you communicate directly with us, such as through e-mail, phone or letter, for example:
- when you complete our online application form, your details will be stored;
- if you take out an agreement with us, we will ask that you provide us with documents to support your application, such as proof of address and income. Copies of those documents may be made and retained;
- during the currency of any agreement with us, we will make notes of any instances of contact between us, which will include any personal information disclosed to us during that contact;
- any calls made to us or our representatives may be recorded for training and monitoring purposes; and/or
- after your agreement has been completed, we may keep records of any feedback you give us about the service provided.
The type of data collected may include personal information such as your name, address, telephone numbers, e-mail addresses, date of birth and employment details. It may also include details of the agreements you have had with us in the past or unsuccessful applications for further credit. You may also disclose sensitive information to us (such as, information about your physical and mental health, racial or ethnic origin, political opinions, religious beliefs, sexual life, medical information), which we may hold and process. Wherever possible we will always ask your explicit consent to process this information.
You are responsible for providing valid, accurate and up to date information. When you give us information about another individual or organisation it is on the basis that you confirm that they have specifically agreed to this and understand how and why their information will be used.
Data Protection Law
Data Protection Law (which includes the General Data Protection Regulation also referred to as GDPR and Data Protection Act 2018) places obligations on us in relation to the way we handle your personal information. The law permits us to use personal information only if we have a proper reason to do so. The law states we must have one or more of these reasons:
- To fulfil a contract, we have with you; or
- when it is our legal duty; or
- when it is in our legitimate interest; or
- when you consent to it.
A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.
How we use your personal information
Your data will always be dealt with responsibly and in accordance with the Data Protection Act 2018 and GDPR. Information stored or collected about you helps us improve our service and helps to make sure that any agreement you have with us is run smoothly.
For example, your information may be used to:
- Identify you when you contact us;
- carry certain credit checks through licensed credit-referencing agencies and a record of this search will be made on your credit profile;
- carry out business processes such as valuing your vehicle so we can provide or assist you in obtaining such products and services which you require;
- make credit decisions about you and check the details that you have provided to us are complete and accurate;
- administer and manage any application you make to us and, in the event you take out credit with us, to administer your account with us;
- monitor and analyse our business including conducting internal audits, using statistical analysis to develop and improve our products and services and conducting market research;
- contact you by e-mail, text message, post, telephone or in any other way about our products and services or the products and services of carefully selected and trusted partner organisations, unless you tell us that you prefer not to receive marketing;
- to identify, prevent, detect or tackle fraud, money laundering, terrorism and other crimes;
- trace your whereabouts and recover any debt you owe us; and/or
- comply with our regulatory obligations.
Any debit card details provided to us either during the loan application or subsequently, will be used to take further payments both on your current loan and on any subsequent loans in accordance with the instructions you’ve given us.
Our payment service provider participates in account update services to help keep your card details up to date and ensure your payments occur without interruption. If your card issuer participates in Account Updater and provides expiration date updates, those updates will apply to your payment towards Loans 2 Go. If your card issuer reissues the card that you have chosen to use for continuous payment authority, we will use the new card details for future payments.
Groups of Personal Information
We use many different kinds of personal information as given below.
|Type of personal information||Description|
|Financial||Your financial position, status and history.|
|Contact||Where you live and how to contact you.|
|Socio-Demographic||This includes details about your work or profession, nationality where you fit into general social or income groupings.|
|Transactional||Details about payments to and from your accounts including bank statements.|
|Contractual||Details about the products or services we provide to you.|
|Locational||Data we get about where you are, such as may come from your mobile phone, the IP address where you connect a computer to the internet.|
|Behavioural||Details about how you use our products and services.|
|Technical||Details on the devices and technology you use to interact with us.|
|Communications||What we learn about you from letters, emails and conversations between us.|
|Your family, friends and other relationships.|
|Open Data and Public Records||Details about you that are in public records and information about you that is openly available on the internet.|
|Documentary Data||Details about you that are stored in documents in different formats, or copies of them. This could include things like your passport, drivers’ licence or birth certificate.|
|Special types of data||The law and other regulations treat some types of personal information as special. We will only collect and use these types of data if the law allows us to do so:
• Health data including gender
|Consents||Any permissions, consents or preferences that you give us. This includes things like how you want us to contact you, whether you get paper statements, or prefer large-print formats.|
|National Identifier||A number or code given to you by a government to identify who you are, such as a National Insurance number.|
Where we collect personal information from
We may collect personal information about you using the information you give to us:
- When you talk to us on the phone or in person.
- When you use our websites, mobile device apps, web chat, emails us and send us letters.
- When you give us access to your bank/building society transaction data/statements.
- In insurance claims or other documents.
- In financial reviews and assessments.
- In customer surveys.
- If you take part in our promotions.
- Payment and transaction data.
Data from third parties we work with:
- Companies that introduce you to us.
- Credit reference agencies.
- Banks and Building Societies.
- Comparison websites.
- Fraud prevention agencies.
- Payroll service providers.
- Land agents.
- Public information sources such as Companies House.
- Agents working on our behalf.
- Market researchers.
- Medical practitioners*.
- Government and law enforcement agencies.
*For some financial assessment, we may ask you to ask your GP or other medical professional to send us a report. We will only use this if we get your consent.
Who we share your personal information with
We may act as broker as well as direct lender. Thus, it may be necessary to disclose your information to our partners to provide you with the products or services you request. However, we will only disclose your information to such third parties where we have your consent to do so via an ‘opt in’ mechanism on our website or other similar channels. We may also disclose your information to third parties where we have a legitimate business need or obligated to do so by law.
We may share your personal information with these organisations:
- Agents who we use to help run your accounts and services, collect what you owe, and explore new ways of doing business.
- Credit reference agencies.
- Fraud prevention agencies.
- Payment services providers.
- Regulators, government authorities, our trade association or other authorities to assist in the resolution of a complaint, to help prevent or detect fraud or terrorism, or for any other reasonable purpose identified by such authority.
- Lenders and debt collection agencies.
- Any company or person to whom we sell or transfer our business or our rights under any agreement we may have with you.
- Any authorised third party linked with you such as Citizen Advice Bureau, PayPlan etc.
- Organisations that introduce you to us.
- Companies that we introduce you to. E.g. Credit Brokers or Lenders.
- Market researchers.
- Companies you ask us to share your data with.
We may also act as broker as well as direct lender. Thus, we may share some of your information with our carefully chosen credit brokers and/or lenders who are authorised to provide information on certain products and services that might be of interest to you. This may involve completing further credit checks and you may receive additional information directly from these third-party companies. However, we will only disclose your information to such third parties where we have your consent to do so via an ‘opt in’ mechanism on our website or other similar channels. We may also disclose your information to third parties where we have a legitimate business need or obligated to do so by law.
Nouveau Finance Limited. http://www.nouveaufinance.com/our_secure_data_handling_rules
Smartping, registered Trading Name of MindFlow Marketing Ltd. https://www.smartping.com/Home/Privacy;
T Dot UK Limited https://t.uk/privacy-policy/
How we use your information to make online decisions
We use a system to decide whether to lend money to you apply for credit. This is called credit scoring. It uses past data to assess how you’re likely to act while paying back any money you borrow. This includes data about accounts you may have had before. Credit scoring will take account of information you provide on your application, information provided by credit reference agencies and information already held on our system. If you submit an application and it is declined through this process, you can contact us within 14 days to have the decision reviewed.
Credit Reference Agencies (CRAs)
We carry out credit checks when you apply for credit. We may use Credit Reference Agencies to help us with this. Your loan application will be registered on your credit report under the name Loans 2 Go Limited. We are presently working with TransUnion, Equifax, Experian and Perfect Data Solutions Limited (trading as Lending Metrics). We will undertake a search with at least one of the agencies when you apply for credit thereby reviewing your credit records as well as anyone financially associated with you. The agency will keep a record of this search and place a “footprint” on your file, whether or not your application proceeds. Once you take a loan product with us, we will report regularly to the CRAs on your payment history.
We will share your personal information with CRAs, and they will give us information about you.
The data we exchange can include:
- Name, address and date of birth.
- Credit application.
- Details of any shared credit.
- Financial situation and history.
- Public information, from sources such as the electoral register and Companies House.
We’ll use this data to:
- Assess whether you are able to afford to make repayments.
- Make sure what you’ve told us is true and correct.
- Help detect and prevent financial crime.
- Manage accounts with us.
- Trace and recover debts.
- Make sure that we tell you about relevant offers.
- Inform you about new services and changes.
We will go on sharing your personal information with CRAs for as long as you are a customer. This will include details of your repayments and whether you repay in full and on time. The CRAs may give this information to other organisations that want to check credit status. We will also tell the CRAs when you settle your accounts with us.
If you are making a joint application or there is an indication that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. CRAs will also link your records together and these links will remain on your and their files until you or your partner successfully files for a disassociation with the CRAs to break that link.
When we ask CRAs about you, they will note it on your credit file. This is called a credit search. Other lenders may see this, and we may see credit searches from other lenders.
You can find out more about the CRAs on their websites, in the Credit Reference Agency Information Notice. This includes details about:
- Who they are
- Their role as fraud prevention agencies
- The data they hold and how they use it
- How they share personal information
- How long they can keep your data
The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at
Perfect Data Solutions Limited: www.lendingmetrics.com
You can contact Lending Metrics at Lancaster Court, 8 Barnes Wallis Road, Fareham, Hampshire PO15 5TU in writing to request the information that they hold about you (please note, a small statutory fee may be payable).
Fraud Prevention Agencies (FPAs)
We may need to confirm your identity before we provide products or services to you. Once you have become a customer of ours, we will also share your personal information as needed to help detect fraud and money-laundering risks. We use Fraud Prevention Agencies to help us with this.
Both we and fraud prevention agencies can only use your personal information if we have a proper reason to do so. It must be needed either for us to obey the law, or for a ‘legitimate interest’.
We will use the information to:
- Confirm identities
- Help prevent fraud and money-laundering
- Fulfil any contracts you have with us.
- We or an FPA may allow law enforcement agencies to access your personal information. This is to support their duty to detect, investigate, prevent and prosecute crime.
FPAs can keep personal information for different lengths of time. They can keep your data for up to six years if they find a risk of fraud or money-laundering.
The information we use
These are some of the kinds of personal information that we use:
- Date of birth
- Residential address
- History of where you have lived
- Contact details, such as email addresses and phone numbers
- Financial data
- Employment details
- Vehicle details
- Automated decisions for fraud prevention
The information we have for you is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.
We and FPAs may process your personal information in systems that look for fraud by studying patterns in the data. We may find that an account is being used in ways that fraudsters work. Or we may notice that an account is being used in a way that is unusual for you. Either of these could indicate a possible risk of fraud or money-laundering.
How this can affect you
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.
Data transfers out of the EEA
FPAs may send personal information to countries outside the European Economic Area (‘EEA’). When they do, there will be a contract in place to make sure the recipient protects the data to the same standard as the EEA. This may include following international frameworks for making data sharing secure.
Sending data outside of the EEA
We will only send your data outside of the European Economic Area (‘EEA’) to:
- Follow your instructions.
- Comply with a legal duty.
If we do transfer information outside of the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA.
If you choose not to give personal information
We may need to collect personal information by law, or under the terms of a contract we have with you. If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services needed to run your accounts or policies. It could mean that we cancel a product or service you have with us. Any data collection that is optional would be made clear at the point of collection.
We may use your personal information to tell you about relevant products and offers. This is what we mean when we talk about ‘marketing’.
The personal information we have for you is made up of what you tell us, and data we collect when you apply for credit. As part of our application process, we will ask you whether we may contact you in future about products and services offered by our organisation or trusted third parties. You can also ask us to stop sending you marketing messages by contacting us at any time. Whatever you choose, you’ll still receive your contractual letters and annual statements related to your agreement.
We may ask you to confirm or update your choices, if you take out any new products or services with us in future. We will also ask you to do this if there are changes in the law, regulation, or the structure of our business.
If you change your mind you can update your choices at any time by contacting us. Our contact details are as follows:
Loans 2 Go Limited, Bridge Studios, 34a Deodar Road, Putney SW15 2NN
Tel: 0330 400 4381; E-mail: firstname.lastname@example.org
How long we keep your personal information
We will keep your personal information for as long as you are a customer of Loans 2 Go.
After you stop being a customer, we may keep your data for up to 6 years for one of these reasons:
- To respond to any questions or complaints.
- To show that we treated you fairly.
- To maintain records according to rules that apply to us.
- To tell you about relevant products and offers unless you’ve told us to exclude you from our marketing campaign.
We may keep your data for longer than 6 years if we cannot delete it for legal, regulatory or technical reasons. If we do, we will make sure that your privacy is protected and only use it for those purposes.
If you made a loan application or enquiry which did not result in a loan, we may keep your data for up 1 year following your loan application/enquiry.
How to get a copy of your personal information
You can access your personal information we hold by writing to us at this address:
Loans 2 Go Limited, Bridge Studios, 34a Deodar Road, Putney SW15 2NN
Letting us know if your personal information is incorrect
You have the right to question any information we have about you that you think is wrong or incomplete. Please contact us if you want to do this.
If you do, we will take reasonable steps to check its accuracy and correct it.
What if you want us to stop using your personal information?
You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.
There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.
We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights. In this situation, we would not use or share your information in other ways while it is restricted.
You can ask us to restrict the use of your personal information if:
- It is not accurate.
- It has been used unlawfully but you don’t want us to delete it.
- It not relevant any more, but you want us to keep it for use in legal claims.
- You have already asked us to stop using your data, but you are waiting for us to tell you if we are allowed to keep on using it.
If you want to object to how we use your data or ask us to delete it or restrict how we use it or, please contact us.
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. 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 customer’s best interests.
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.
Further information about Open Banking is available from www.openbanking.org.uk.
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.
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.
How will my Shared Personal Data and Transaction Information be used?
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.
As PDS are also a credit reference agency they may also share and keep a record of your Shared Personal Data and Transaction Information.
Will you use my Transaction Information data for any other purpose?
Do I have to provide you with my consent to proceed?
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.
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.
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.
How to complain
Please let us know if you are unhappy with how we have used your personal information. To contact us please see our https://loans2go.co.uk/complaints-data/
If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law you can complain to the Information Commissioner’s Office https://ico.org.uk
|Version||Change Date||Details of Change||Approval|
|1||September 2016||New Policy||Chief Risk Officer|
|2||May 2018||GDPR compliance reviewed||Chief Risk Officer|
|2.1||November 2018||Brokerage requirements||Chief Risk Officer|
|3||January 2019||Lending Metric notice inserted||Chief Risk Officer|
|3.2||July 2019||Company Logo updated||Head of Compliance|
|4||July 2020||Account update added and broker listing amended.||Chief Risk Officer|
|5||June 2021||Information related to financial associate added||Chief Risk Officer|
|6||July 2021||Information and names related to CRA||Chief Risk Officer|