For the purpose of the Data Protection Act 1998 (the "Act"), the data controller is AvantCredit of UK, LLC. Our Information Commissioner’s Office Data Protection registration number is ZA001503. In addition, AvantCredit of UK, LLC is authorised and regulated by the Financial Conduct Authority. Our Firm Reference number is 727347.AvantCredit Respects Your Privacy
We respect your privacy and are dedicated to only the highest level of integrity in all of our dealings with our customers. We are focused on protecting personal privacy, and safeguarding confidentiality and system security. We are dedicated to upholding the highest ethical standards in our business practices and aim to collect, use and disclose Personal Data in a manner consistent with the laws of the countries in which we do business.
We collect Personal Data directly from you when you use our services, including the Website. As a processor of loan transactions and a provider of related services, we also obtain and receive Personal Data from financial institutions and other entities in connection with loan transactions ("Members"). In cooperation with our Members, we seek to ensure that such Personal Data are adequately protected under data protection law.Personal Data We Collect
We may collect and process the following information about you:
- Any information provided by you:
- through our loan applications, questionnaires, on-line forms, and/or other entries, including but not limited to names, date of birth, home address(es), telephone number(s), email address(es), financial information (such as bank account details), employment information, demographic information, government issued identification number, salary, user IDs and passwords, product and service preferences, and contact preferences; and
- by corresponding with us by phone, SMS/text message, email, letter or otherwise;
- Any information about your transactions with us, such as payment history and loan balances, and information provided when interacting with our customer service representatives;
- Any information we receive from our affiliates and third parties about you, such as credit reporting agencies, consumer reporting agencies and other lenders, concerning creditworthiness, credit history, and loan repayment history;
- Any information relating to other websites which visitors to our Website access;
- Any website http headers (home server domain names, IP addresses, types of client devices, and type of Web browsers)connected with your access to our Website;
- Information regarding whether you have selected the images and/or links on our Website in order to confirm that we are providing relevant materials to you;
- Details regarding when email communications to you were opened and whether your computer or other device is capable of receiving HTML-based email messages, which are tracked using a coded sensor activated upon the opening of the email;
- Any email addresses that you use to communicate with us via email; and
The Personal Data we collect is used to understand your needs and interests and helps to deliver a consistent and personalized experience. We may use your Personal Data:
- To carry out our obligations arising from any loan transactions entered into between you and us and to provide you with the information, products and services that you request from us;
- To provide you with information about other products and services we offer that are similar to those that you have already entered it, requested or enquired about;
- To update you regarding new services and benefits;
- To select content to be communicated to you and to provide personalised promotional offers;
- To transmit marketing communications and to measure performance of marketing initiatives, ads, and websites provided by another company on our behalf;
- To ensure that content from our Website is presented in the most effective manner for you and for your computer or other device;
- To administer our Website, enhance operational capabilities and for internal operations, including troubleshooting, data analysis, testing, research, statistical analysis and survey purposes;
- To improve our Website and to improve your experience with our Website and to ensure that content is presented in the most effective manner for you and for your computer or other device;
- To allow you to participate in interactive features of our service, when you choose to do so;
- As part of our efforts to keep our site safe and secure;
- To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- To protect against misuse or unauthorised use of our Website;
- To prevent and detect security threats, fraud, money laundering or other malicious activity; and
We may also use your Personal Data in the following ways in order to process a loan transaction:
- To verify your identity;
- To verify your credit status;
- To assess your credit history;
- To confirm your employment details;
- To assist you in completing a transaction or order;
- To administer your loan;
- To manage your account;
- To collect and process payments;
- To enforce any loan in default and recover any debts owed by you;
- To contact and communicate with you regarding the loan transaction;
- To provide and improve customer service and support;
- To keep our records up-to-date;
- To notify you about changes to our services;
- To deal with any complaints;
- To pursue any claims brought by you; and
- To ensure legal compliance.
We may combine information received about you from third parties with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).How Long Do We Keep Personal Data?
We will keep your Personal Data to enable us to provide the requested products and services that you are receiving from us. We may still need to keep your Personal Data to ensure that our systems reflect your preferences even if you have opted out of allowing us to use your Personal Data for marketing purposes. We may keep records of any transactions you enter into on the Website for a minimum of six years from the end of our relationship with you and until no longer needed. We may keep other information about you only to the extent necessary to comply with applicable laws and to further legitimate business needs.Privacy Principles
Our activities relating to the collection, storage, use, transfer, and other processing of your Personal Data are based on the following principles:
Where we collect Personal Data directly from you, we will inform you of the purposes for which we collect and use this Personal Data and the choices and means, if any, we offer you for limiting the use and disclosure of your Personal Data. Notice will be provided in clear language when you are first asked to provide Personal Data to us, or as soon as is practical. Notice will also be provided before we use or disclose your Personal Data for a purpose other than that for which it was originally collected or before we disclose it to a third party who is not engaged to perform services on AvantCredit’s behalf. In addition, we reserve the right to use and disclose all information about you, your loan transaction and your use of our Website that is not in an individually identifiable form, as we deem appropriate.
You may contact us at any time as indicated in the "Contact" section below regarding our use or disclosure of your Personal Data.
At times we may receive Personal Data from our Members about individual customers which we do not have a direct relationship with. We have advised our Members that they are responsible for providing those individuals with a choice regarding whether their Personal Data may be disclosed by us to third parties who are not acting on our behalf or used for a purpose other than that which the information was originally authorised by the individual to be gathered.
We use Personal Data in a manner which is consistent with the purposes for which it was collected or subsequently authorised by you. We will take reasonable measures to ensure that Personal Data is accurate, complete, and current. We only collect and store Personal Data that is directly relevant for the purpose for which it is intended and will keep any such Personal Data in accordance with the timeframes described above in the "How Long Do We Keep Personal Data?" section above.
Storage and Transfer of your Personal Data
We have developed our privacy policies and standards by complying with the principles developed by the international community, including but not limited to EU Directive 95/46/EC regarding the collection, use, and retention of Personal Data from EU member countries. Countries within the EEA are required to have a similar standard of protection of Personal Data.
The Personal Data that we collect from you may be transferred to, and stored at, a destination outside the EEA, including to the United States of America. It may also be processed by staff operating outside the EEA who work for us, for our affiliates or for one of our suppliers. Such staff may be engaged in, among other things, administering your loan, managing your account, collection and processing of payments and the provision of support services. Before we transfer your Personal Data in this manner we will take all steps reasonably necessary to ensure that any such transfer is made securely and that there is adequate protection in place in order to protect your Personal Data, as required by the Act and any other applicable data protection legislation.
Access to your Personal Data
The Act gives you the right to access information held about you. Your account can be accessed and certain Personal Data can be updated by you via the password-protected access portal on the Website. We will also take reasonable steps to permit you to correct, amend, or delete information that is shown to be inaccurate or incomplete.
Upon request, we will grant you reasonable access to any additional Personal Data that is maintained. These requests can be made by emailing us at resolutions@AvantCredit.co.uk. We reserve the right to charge a fee of up to £10 for any request for us to provide you with details of the Personal Data we hold about you.
We will take reasonable measures to protect Personal Data in our possession from loss, misuse and unauthorised access, disclosure, alteration and destruction. Personal Data is secured by us in the following ways:
- Personal Data is stored in a restricted access format;
- Personal Data will be transmitted in an encrypted format using Secure Sockets Layer (SSL) software;
- Relevant networks are secured with certified firewalls in a multi-layered manner with redundancy;
- Our customer service representatives are only provided with limited access to Personal Data; and
- Network related equipment is secured with a password, and access is limited to authorised network engineers who support our equipment, systems and the Website.
Where we have given you (or where you have chosen) a password 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.
How We May Share Personal Data
We will keep your Personal Data confidential, except where disclosure is permitted as described in this section.
When you provide your Personal Data to us, you acknowledge and agree that we may share any such Personal Data with our affiliates and third parties acting on our behalf as outlined below. When you communicate with us, your communication may be randomly monitored or recorded to protect the interests of our business and our customers. This includes maintaining high quality standards to ensure that our employees comply with legal obligations and our policies and practices. We contract with service providers to perform certain functions on our behalf, such as database providers that provide assistance in verification of identity, publishers, retailers, direct marketers, site analysis firms and loan administration service providers. These service providers have limited access to your Personal Data and only to the extent necessary to perform these functions on our behalf. They are required to comply with our instructions and are strictly prohibited from using or disclosing your Personal Data for any other purposes.
We set out below the key third parties that we may provide your Personal Data to.
Fraud prevention agencies
If false or inaccurate information is provided by you and we have grounds to suspect fraud (or we identify fraud), details relating to any such information, including Personal Data, may be shared with the applicable fraud prevention agencies. In addition, law enforcement agencies may access and use any such fraud related information. We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when;
- Checking details on applications for credit and credit related or other facilities;
- Managing credit and credit related or facilities;
- Recovering debt;
- Checking details on proposals and claims for all types of insurance; and/or
- Checking details of job applicants and employees.
Credit reference agencies
Credit references are used to evaluate any application for credit you may make and verify your identity to preclude criminal activity. We reserve the right to make reasonable periodic inquiries with credit reference agencies ("CRAs") in order to update records and manage your account(s). You may contact these CRAs but you may be required to pay a small statutory fee in order to obtain any such information they hold about you.
When a CRA receives a request for information from us, they will place a search "footprint" on your credit file that may be seen by other lenders when you apply for credit in the future. We are provided with information relating to previous applications and activity of accounts held in your name and/or of your associate(s), public information such as County Court Judgements (or decrees in Scotland) and bankruptcies, electoral Register information, and fraud prevention information.
When information is supplied to a CRA regarding your account(s) the CRA will record the details that are supplied on your personal and/or business account (if you have one) including any previous and subsequent names that have been used by the you and how the account is managed. 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 to perform similar checks and to trace your whereabouts and recover debts that you owe. Records remain on file for 6 years after they are closed, whether settled by you or defaulted.
The credit reference agencies we might use may include the following:
- Equifax PLC, Credit File Advice Centre, PO Box 3001, Bradford, BD1 5US or call 0870 010 0583 or log on to www.myequifax.co.uk
- Experian, Consumer Help Service, PO Box 8000, Nottingham NG80 7WF or call 0844 4818000 or log on to www.experian.co.uk
- CallCredit, Consumer Services Team, PO Box 491, Leeds, LS3 1WZ or call 0870 0601414
We may disclose your Personal Data to our affiliates from time to time to: (i) further administrative and compliance activities; (ii) evaluate credit worthiness and other risks; (iii) develop customer relationships and services; and (iv) enable our affiliates to contact you for marketing purposes.
We may also disclose your Personal Data: (i) to the extent that we are required to do so by law (for example to government bodies and law enforcement agencies) and/or permitted by the provisions of the Act; (ii) in connection with any legal proceedings or prospective legal proceedings or for establishing, exercising or defending legal rights; (iii) to the purchaser or seller of or investor in any business or asset (including the sale or transfer of a loan) which we are (or are contemplating) selling or purchasing and their advisors or service providers; or (iv) third parties who act for or on our behalf. In the event of a purchase or sale of any business or asset, or the sale or transfer of a loan, there may be a change of data controller.
Marketing and Opt-Out Rights
By submitting Personal Data to the Website, you, understand and agree to allow us and our affiliates to use any Personal Data you have provided in order to contact you via postal service or telephone to provide assistance with your loan and/or to discuss other products and services provided by us.
Unless you have opted out we may also contact you via email, SMS/text message or other electronic mail to inform you about other products or services provided by us that are similar to those that you have already agreed to, requested or enquired about or we may also contact you via email, SMS/text or other electronic mail message to inform you about other products or services provided by us if you have consented to receiving such marketing communications.
You have the right to ask us not to use your Personal Data for marketing purposes. You can exercise this right at any time by notifying us using the contact details set out in the "Contact" section below
Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of those websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to those websites.
"Cookies" are small data files that websites download to a user’s computer, mobile phone or tablet hard drive. Most web browsers automatically accept cookies. We or our service providers send cookies when you visit our Website or websites where our ads appear, make purchases, request or personalise information, or register yourself for certain services. Accepting the cookies used on our Website, sites that are provided by another company on our behalf, or sites where our ads appear may give us access to information about your browsing preferences, which we may use to improve the services we provide to our users, and to personalise and enhance your user experience. We use similar technologies within emails to understand whether the email has been read or if any links have been clicked by you. Cookies are typically classified as either "session" cookies or "persistent" cookies.
- Session cookies do not remain on your computer after you close your browser.
- Persistent cookies remain on your computer or other device until you delete them or they expire.
You can reject cookies or selectively accept cookies by activating the setting on your browser that allows you to refuse all or some cookies. If cookies are not accepted, there may be some features of our Website that will not be available and some websites may not display properly. In most instances, however, you may reject a cookie and still be able to navigate our Website without issue. Information on how to adjust cookie preferences (e.g., preventing your browser from accepting new cookies, etc.) are located in the help and support section of your browser. If you continue to use our Website without changing your settings, we will assume that you agree to receive all cookies on the Website.
We DO NOT store passwords or any other information about a visitor in a cookie that would identify them, locate them, and determine their preferences or their financial activity. Aggregated customer information may help assess the performance of our Website and develop strategies to maximise utility. This information may be provided to other companies, including but not limited to third party advertisers. This information does NOT include any of your Personal Data.
The cookies that we use on the Website and the purpose of their use are:
- Adalyser- Third party, persistent cookies used to support tv tracking system;
- Adroll- Third party, persistent cookies used to retarget visitors on other websites, or exclude them from said remarketing and records a conversion when user who has seen or clicked an ad reaches a defined point in our conversion funnel;
- Olark- Session and persistent third party cookies used to support the Olark chat systemhat system cookies;
- Optimizely- Third party, persistent cookies used for A/B test experiments;
- Atlas- Third party, persistent cookies used to tie back an activity on our website to an earlier activity on a third party website;
- AA003- Third party, persistent cookies used to tie back our people-based metrics in reporting;
- Responsys- Third party, persistent cookie used to track what stage a user reaches on our application via our email marketing platform;
- Kenshoo- Third party, persistent cookie used for website conversion tracking;
- Heap - Third party, session and persistent cookies used for web analytics;
- Security Cookies – Session cookies used to support security measures within the site;
- Yield Manager – This is a tracking pixel that records traffic coming from 3rd party sources;
- LivePerson – A tracking pixel used to track web session for customer service web chat;
- AvantCredit – Contains a session cookie recognizing applicant to process loan application through completion for internal logging;
- Iovation – Contains a cookie to identify applicants electronic device;
- DoubleClick – This is a tracking pixel that records traffic coming from 3rd party sources;
- H Online – Contains a cookie to identify applicants electronic device;
- Google Analytics – A third party, persistent cookie which supports web analytics tracking; and
- Google Adwords – Conversion tracking.
From time to time, audits will be conducted of our privacy practices to verify adherence to any and all applicable laws, rules and regulations. In the event that a finding is made that an employee of ours has intentionally violated this Policy, we may impose disciplinary measures including, but not limited to, termination of their employment.
We do not seek or knowingly collect any Personal Data about children under 18 years of age. We do not target our websites to children under 18 years of age and will delete any such Personal Data which we become aware of. We encourage parents and guardians to take an active role in their children's online and mobile activities and interests.
This Policy may be amended from time to time. We may also update this Policy to reflect changes in our services. When changes are made to this Policy, the "last updated" date located at the bottom of this Policy will be adjusted accordingly. In the event this Policy is changed in a material way or if there are material changes to how we use your Personal Data, we will advise you by posting a notice regarding the changes on our Website for 60 days or by sending notification via email to the email address you have provided. Please check our Website frequently to see any updates or changes to this Policy.
To contact us about questions or comments about this Policy or practices concerning Personal Data, please email us at firstname.lastname@example.org or write to us at:AvantCredit
222 Regent Street
London W1B 5TR
1 February 2017.