How we use your information
Information we hold about you
This policy applies to information we hold about you. ’You’ means the person the information relates to. In this policy ’we,’ ’us’ and ’our’ means Custom Credit, which is a trading name of Custom Credit Limited. Custom Credit Limited is authorised and regulated by the Financial Conduct Authority (Financial Services Register number: 961764). Registered in England. Registered No: 13288592. Registered Office: Basepoint Centre, Little High Street, Shoreham-by-Sea BN43 5EG.
This policy applies to information we hold about customers and possible future customers, suppliers and possible future suppliers, contacts, and all other people we hold information about. By ’information’ we mean personal and financial information about you that we collect, use, share and store. For further details on the information about you that we may process, please call us on 0800 802 1466.
Where this information comes from
We collect, use, share and store information about you to provide you with the services you have asked us for and to share information with you about services that may be of interest to you. We will collect your information direct from you or from other people and organisations. For more details of where we may get your information from see www.customcredit.co.uk/privacy-policy
How we use your information
We use your information:
• to provide our services to you;
• to help us develop new and improved products and services to meet our customers’ needs;
• for security and to check your identity;
• for training;
• to communicate with you;
• for legal reasons;
• where we have a legitimate interest in using your information, for example to protect our business interests, to meet our regulatory responsibilities or to prevent fraud; and
• to keep you informed about products and services you hold with us and to send you information about products or services (including those of other companies) which may be of interest to you.
We may use automated processes. For further information, including the legal basis on which we use your information, please see www.customcredit.co.uk/privacy-policy/.
Sharing your information with others
We’ll keep your information confidential, but we may share it in certain circumstances, for the purposes set out in this policy, with:
• other companies who provide a service to you, for example if you use our
products to make a purchase or payment;
• our service providers and agents, including their subcontractors;
• any company we are providing services with;
• anyone we transfer or may transfer our rights and duties to;
• fraud prevention agencies, who will use it to prevent fraud and money laundering and to confirm your identity (if fraud is detected, you could be refused certain services, finance, or employment); and credit reference agencies.
The people and organisations listed above will also have to keep it secure and confidential.
Credit reference agencies and fraud prevention agencies
In order to process your application, we will give your personal information to credit reference agencies and fraud prevention agencies, and they will give us information about you, such as about your financial history. We do this to assess your creditworthiness (how likely you are to be able to repay the money), make sure the product is suitable for you, check your identity, manage your account, trace, and recover debts and prevent criminal activity.
These agencies may in turn share your personal information with other organisations. If fraud is detected, you could be refused certain services, finance, or employment.
If you give us false or inaccurate information and fraud is identified, we may pass details to credit reference and fraud prevention agencies to prevent fraud and money laundering and to check your identity.
The Credit Reference Agency Information Notice (CRAIN) describes how the three main credit reference agencies in the UK each use and share personal information. The CRAIN is available on the credit reference agencies’ websites:
Or you can ask us for a copy of these.
For further details of who we may share your information with, and how your information will be used by us, fraud prevention agencies and others, please call us on 0800 802 1466.
How long we will keep your information
We will keep your information for as long as is needed for the purposes set out above or as required by any laws that apply.
If you close your account, if we refuse your application for an account or product, or you decide not to go ahead with your application for an account or product, we’ll still keep your information. We may also continue to collect information from credit reference agencies to use after your account is closed. We’ll do this for as long as we’re allowed to for legitimate business purposes, to help prevent fraud and other financial crime, and for other legal and regulatory reasons.
You have rights relating to the way that we use your information and can make certain choices. For example, you can:
• ask for a copy of the personal information we hold about you;
• ask us to correct your personal information if necessary;
• withdraw any permission you have previously given relating to your personal information;
• object to any automated decision-making;
• ask us to stop or start sending you marketing messages;
• ask us to send you (or someone you nominate) a copy of the information we hold about you; and
• ask us to stop using your information in certain circumstances.
To use any of the rights set out above, or to discuss any other issue relating to your information, please contact us using the methods set out in the ‘Contact us’ section.
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 consumer’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.
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?
The Transaction Information we receive about you will only be used for the Permitted Purpose. We do not sell or share Transaction Information with any third party.
Do I have to provide you with my consent to proceed?
We ask for your consent at application and then routinely through the life of your agreement. You can always check the consent status by logging into the web portal or application.
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.
If you have data privacy concerns.
If you have any concerns about the way we use your information, you have the right to complain to the Information Commissioner’s Office, which regulates the use of personal information in the UK, by calling 0303 123 1113.
For further details on your rights relating to the way we use your information, and other ways to contact us, please call us on 0800 802 1466.
If you have any questions or comments about privacy issues, or you have a complaint about how we are using your personal information, you can call us on 0800 802 1466.