Privacy Policy

During the enquiry / application process and during the life of the loan we may collect personal and financial information including (but not limited to):

• Name, address & postcode
• Employment details and income (including details of benefits / secondary income)
• Details of outgoings / monthly expenditure, financial information and bank details
• Date of birth
• Contact information including telephone number(s) and email addresses
• Address (residential) history
• Current and historic credit history (such as loan amounts, outstanding balances, payment history etc.)
• The performance of your loan (if you make payments, should you take a loan with MML)
• Vehicle details including vehicle registration number
• Identifiers assigned to your computer (or other internet connected devices), including your Internet Protocol (IP) address and visits to our website (including traffic data, location data). Please see our Cookies policy for more information.
• Information and correspondence provided by you or obtained from third parties, such as fraud prevention agencies, credit reference agencies and law enforcement.

We do not request or process ‘sensitive’ information (health, medical records etc.) during the application process. If sensitive information is provided to us, we will ask for your explicit consent prior to recording it.

Legal basis for processing personal data – Contract

When we process your personal data, including conducting credit searches (if applicable), we do so on the basis that we must do so to progress the loan enquiry / application process, with a view to entering into the loan contract. Such processing is a requirement of the finance you have requested.

We will not be able to provide you with a loan or service if you do not supply us with the necessary information.

How will we use the information we collect about you?

The information gathered is used for the following reasons:

• To process your loan application
• Assess your credit profile
• Carry out credit searches (if applicable) and checks with fraud prevention agencies
• In some cases, to electronically verify your identity, income & bank account
• Share your information with, and obtain information about you from credit reference agencies and/or fraud prevention agencies
• To administer your loan and manage your account
• To record and respond to complaints

• To improve our products, website and services
• Statistical analysis
• To meet our legal and regulatory obligations and for crime and fraud detection/prevention

Our commitment to you about your personal information

We will treat all your information as private and confidential (even when you are no longer a client).

We will not give your data to anyone else unless we have your express consent, except where we are required to do so by law or asked to do so by a court or regulator, or where the disclosure is made at your request or with your consent.

Where a third party, for example a credit broker or price comparison website, has introduced your application to us, we may disclose information concerning the progress of your application to them.

Accuracy of the data we hold about you

If you have reason to believe that the data we hold about you is inaccurate, please contact MML’s Data Protection Officer (see “Contacting Us”) providing full details of the error.

We will promptly correct any information confirmed to be incorrect.

Future marketing

If you have provided your consent, we will keep you informed of new products, and additional borrowing offered by Mobile Money Limited.

Depending on your preferences, any future marketing contact will be made by either letter, telephone, email, or SMS.

Please note we do not pass your details to any other third parties, for the purposes of marketing, without your explicit consent.

If you would like to update your preferences or would prefer not to be contacted by us, please:

Amend your preference here: Update Marketing Preferences

Or

E-mail your name, address & postcode to:    gdpr@mobilemoney.co.uk

Or

Write to, or telephone, the Data Protection Officer at our Head Office address (see “Contacting Us”) informing us which communication channels you wish to restrict marketing (i.e. Telephone, text, direct mail).

If you wish to unsubscribe from all channels, please confirm that you wish to cease all future marketing.

Please note changes may take up to 30 days to become effective.

Who may we share your personal data with?

If we are seeking to recover an unpaid debt, we may share your details with tracing agents or solicitors, which may trace or communicate with you on MML’s behalf.

We may also share your account information and communicate with your vehicle insurance company, should there be a claim against your vehicle.

Security of your data

MML is committed to ensuring that your personal information is held securely.

We have put in place various controls and procedures to protect and keep secure the information we collect or hold separately.

If you contact MML, you will always be asked a number of security questions before we will discuss your personal details or loan account with us.

Your rights

Your personal data is protected by legal rights, which may include your rights to:

• object to or restrict our processing of your personal data;
• request that your personal data is erased or corrected;
• request access to your personal data.

For more information or to exercise your data protection rights, please contact us using the contact details provided earlier.

MML will correct any data that you are able to evidence is inaccurate and will delete any data that is no longer required (see Retention Periods)

If you are unhappy about how your personal data has been used please refer to our complaints policy.

You also have a right to complain to the Information Commissioner’s Office, which regulates the processing of personal data.  For more information please visit; https://ico.org.uk/for-the-public/

Your right to access information that we hold about you (Subject Access Requests)

We may process and store information about you electronically and/or in manual records. Any such information that is personal data as defined in the Data Protection Act 1998 (“DPA”) will only be used by us for the purposes registered by us under the DPA.

The DPA gives you the right to ask us to provide you with certain information that we hold about you.

Any request in that respect should be made in writing and addressed to our Data Protection Officer.

There is no charge for submitting a Subject Access Request.  To protect your data please note we will ask you to verify your identity prior to MML releasing the information to you.

Upon receipt of a Subject Access Request MML has a maximum of 30 days to respond.

Your data – retention periods / how long we keep your data

Personal data type	Retention period	Retention reason
1.  Loan enquiry made but did not progress to credit search (or no credit search done) – Loan did not complete	Six months – Declined marketing option 12 months – Future marketing agreed	Legitimate interest & Regulatory requirement
2.  Loan enquiry made, credit search carried out but no loan completion	12 months from the date of the search	Legitimate interest & Regulatory requirement
3.  Loan enquiry made, credit search carried and loan provided	Six years from the loan being paid off/written off in full. Five years for Customer documents.	Legitimate interest, Legal & Regulatory requirement
4.  Complaints data	Six years from the end of the relationship.	Legitimate interest & Regulatory requirement (reporting and Disp 1.9
5.  Loan performance information	Six years from the loan being paid off/written off in full.	Legitimate interest
6.  Marketing preference	Indefinitely, until the customer requests to be deleted from future marketing. Each electronic communication will offer an option to opt out.

The customer has access to the marketing preference suite to update their records at any time.Consent

 

The retention period for one through to five is subject to no other overriding obligation to retain details for longer, i.e. Litigation/Court action or Fraud investigation

Credit Referencing

A Guide to the use of your personal and business information by Mobile Money Limited and at Credit Reference Agencies (CRAs) and Fraud Prevention Agencies (FPAs)

1) When you apply to us to open an account, Mobile Money Limited will check the following records about you and others:

• a) Our own
• b) Those at CRAs. When the 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.
• c) Those at FPAs.

The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finances or employment. Further details of how your information will be used by Mobile Money Limited and these fraud prevention agencies and your data protection rights can be found by visiting our website at www.mobilemoney.co.uk.

2) The information will be sent to CRAs and will be recorded by them. Where you borrow from Mobile Money Limited, 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 the debts that you owe. Records remain on file for 6 years after they are closed, whether settled by you or defaulted.

3) If you give false or inaccurate information and we suspect or identify fraud we will record this and may also pass this information to FPAs and other organisations involved in crime and fraud prevention agencies.

4) 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 Data Protection Act 1998. Please visit www.equifax.co.uk/crain for further information.

How to find out more

This is a condensed version and if you would like to read the full details of how your data may be used please visit our website at www.mobilemoney.co.uk or phone 0152768349 and ask one of our staff. You can contact the CRAs currently operating in the UK; the information they hold may not be the same so it is worth contacting them all. They will charge you a small statutory fee. Contact details of each CRA may be found on our website. Please visit www.equifax.co.uk/crain for information on how CRAs handle data.

Please contact us at info@mobilemoney.co.uk if you want to receive details of the relevant fraud prevention agencies.

Credit decision/Scoring

MML will seek further data about you from external sources, such as credit reference agencies.  We will make searches about you at credit reference agencies who will supply us with credit information (including details of your current outstanding debts & repayment profiles), as well as information about your ability to repay the proposed loan (by way of electronic income verification), information from the Electoral Register and information to confirm your identity (by way of electronic identity verification).

Consequences of processing – credit decision/scoring

The information received from credit reference agencies is used to populate a ‘credit scorecard’, which provides a ‘risk score’ and helps us understand behaviour and an individual’s propensity to pay.  This may determine whether you qualify for a loan with MML.

If you are declined for credit, based upon scoring, it will have no wider impact upon your credit file.

Details of the decline will only be retained by Mobile Money Limited.

Credit searches:

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 your financial situation and history. We do this to assess creditworthiness and product suitability, check your identity, verify the accuracy of the data you have provided to us, manage your account (if you take out the loan), trace and recover debts and to prevent criminal activity, money laundering and fraud..

When you enquire, our initial credit search, which is used to generate your loan quote, is a ‘soft’ search (enquiry search) and does not leave a footprint on your credit file.  The agencies will record details of the search whether or not this application proceeds.

The search should not impact upon your credit rating and cannot be seen by other people making searches in the future.

If you decide to proceed with the loan a ‘hard search’, (application search) will be carried out against you. This hard search will be recorded by the credit reference agency and may be seen by other people searching in the future. This is a requirement of the credit reference agency and common practice across the finance industry.

If you obtain a loan with us and whilst your loan account is live, we may make periodic searches at Credit Reference Agencies and Fraud Prevention Agencies so that we can manage your account with us.

Credit reporting:

During the life of the loan, MML will submit details of your account status (balance and whether repayments are made) and how you conduct your account (including defaults) to the Credit Reference Agencies & Fraud Prevention Agencies.

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 information, are explained in more detail at;

https://www.equifax.co.uk/crain

The information recorded by the Credit Reference Agencies will typically remain on your credit file for a period of six years.

If fraudulent activity is detected, MML will submit details to Fraud Prevention Agencies.

Legal basis for processing personal data – Anti-fraud

When we and fraud prevention agencies process your personal data, we do so on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested.

We, and fraud prevention agencies, may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to five years.

Processing – Anti-fraud

As part of the processing of your personal data, decisions may be made to prevent fraud and financial crime.  This means we may decide that you pose a fraud or money laundering risk if:

• our processing reveals your behaviour to be consistent with that of known fraudsters or money launderers; or is inconsistent with your previous submissions; or
• you appear to have deliberately hidden your true identity or falsified documentation.

Consequences of processing – Anti-fraud

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 we may stop providing existing services to you.

A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details above.

Data transfers

Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.

CIFAS Notice

General

1. Before we provide services, goods or financing to you, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you.

2. The personal data you have provided, we have collected from you, or we have received from third parties will be used to prevent fraud and money laundering, and to verify your identity.

3. Details of the personal information that will be processed include, for example: name, address, date of birth, contact details, financial information, employment details, device identifiers including IP address and vehicle details.

4. We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

5. We process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services of financing you have requested.

6. Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

Consequences of Processing

7. 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.

8. A record of any fraud or money laundering risk will be retained by fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details above.

Data Transfers

9. Whenever fraud prevention agencies transfer your personal data outside the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.

Your Rights

10. Your personal data is protected by legal rights, which include your rights to object to our processing of your personal data; request that your personal data is erased or corrected; request access to your personal data.
11. For information or to exercise your data protection rights, please contact us using on our website.
12. You also have a right to complain to the Information Commissioner’s Office which regulated the processing of personal data.

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Please refer to our Complaints Policy