Kidwells Legal Loans Ltd
4 Coldnose Road
Rotherwas Industrial Estate
Regulated by the FCA, no. 723996
Registered in England & Wales, Company no. 08555898
Data Protection Officer: Michael Horne
Email address: email@example.com
Telephone number: 01432 278179
Postal address: as above
The data that we collect
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The data that we may collect or use include:
- Your name, title, date of birth, gender, and other verifiable identity information
- Your contact information such as a residential address, email address, and telephone number
- Business information such as your profession, job title, name of the business, company number, business address, and accounts
- If you take funding from us, payment information such as card details or a bank account number
- If you are a sole trader, information to understand your ability to afford loan repayments, which could include income, expenditure, and number of dependants
- Data from third parties, including contact information, and in the case of credit reference agencies this could include credit information, financial situation or financial history
- Technical information about your use of our website as outlined in our Cookies Policy
- Records of your communication with us, including chat logs, contact forms, emails, and call recordings
- Other information that you might provide voluntarily
These details would be collected online by form, by email, by post, in person, or over the phone for the purposes of checking your eligibility, processing your application should you be eligible, and providing you with a loan should you decide to proceed. Some details, such as your identity, would be verified with ID such as your passport, driving licence, or documents such as utility bills.
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions.
- The right to access the personal data we hold about you.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
What we do with your data
As a responsible lender, we have to undertake checks before we provide services, goods, or financing to you. These checks are for the purposes of preventing fraud and money laundering, to verify your identity, and to make sure you are eligible for a loan and able to repay it.
In full, we use your data to:
- Prevent fraud and money laundering, to comply with our legal obligations
- Verify your identity, to comply with our legal obligations
- Assess you/your business’ eligibility and viability for loan products, to comply with our obligations as a responsible lender
- Set up, administer, and manage your account, to be able to fulfil our contract with you and our legal obligations
- Conduct risk modelling and analysis, to continually improve the service we provide to you and other businesses
- Market our products and services to you (in most cases this is strictly opt-in, and all of which you can choose to opt-out from)
When and how we might share your data
We may share your data with third parties, such as credit agencies, to:
- Assess you/your business’ eligibility and whether you can afford to take the product
- Verify the accuracy of the data you have provided us, such as your identity
- Prevent fraud, money laundering, and other criminal activity
- Manage your account, including conducting ongoing checks to ensure that you/your business remains eligible for the agreed credit facility
- Trace and recover debts if you break your contract with us
- Inform credit agencies about your settled accounts or outstanding payments
As part of our checks, your data may be shared with credit reference, identity verification, and fraud agencies. This is in order to process your application. To do this, we would supply your name, date of birth, and address history to the agencies. Our process uses a “soft check” which will not impact your credit score. To verify your identity, if you aren’t able to provide your ID documents in person, we would verify a scan of your ID document with an agency.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.
When sharing your personal data with other third-party processors, such as credit reference agencies, this data may be may stored on databases outside of the EU. In such cases, we impose contractual obligations on them to protect your data to the same standard required in the UK and the EU. This is to ensure that your data and privacy rights are not infringed. This can also involve third parties being subscribed to recognised international frameworks which are designed to enable secure data sharing. This framework could be the Standard Contractual Clauses, or in the case of the USA, the Privacy Shield certification. Standard Contractual Clauses and confirmation of Privacy Shield certification are available on request.
Please note that our lending decisions are made by humans, not bots or automated processes. If you have any questions about how your personal or business data was used to make a lending decision, please contact us.
How long we store your data
The length of time we retain your data for depends on several factors. This includes the purposes for which the data was collected, whether you have asked us to delete the data, and what legal obligations we have to retain the data. We do not retain data for longer than is necessary to fulfil the purposes under which the data was collected.
If you open an account with us, we will typically keep your data for ten years after you have last had an active account, or after you made or started an application. If needed for legal, operational, or regulatory purposes we might store your data for a longer period.
How we protect your data
We take data security seriously and regularly implement, review, and improve our technological and operational processes to protect personal data. We protect is against unauthorised disclosure, use, alteration, or destruction. A couple of processes, for example, include limiting staff access to strictly what is necessary as well as using two-factor authentication.
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Contact us or make a complaint
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with us or with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first for the attention of:
Telephone number: 01432 278179
Last updated: 30/01/2020