About us & our Privacy Policy:

www.118118money.com is operated by 118 118 Money, which is the trading name of Madison CF UK Limited (Company No: 08393840; Registered office: Fusion Point, Dumballs Road, Cardiff CF10 5BF). We are part of the kgb group of companies, which includes 118 118 and Conduit Global, all together the Group.

118 118 Money is authorised and regulated by the Financial Conduct Authority (FRN: 741774). You can confirm our registration on the Financial Conduct Authority’s website www.the-fca.org.uk or by contacting the Financial Conduct Authority on 0800 111 6768.

If you wish to contact our Data Protection Officer, please contact them via dpo@118118money.com. Other ways to get in touch with us are set out in the Contacting us section below.

Protecting your personal information:

Personal information about you is protected by law which includes the General Data Protection Regulation which comes into
force in the UK on 25 May 2018 (GDPR).  We will update this Privacy Policy to reflect further changes required for the GDPR.

The law regulates how we may process personal information relating to you and grants you various rights in respect of your personal information.

The aim of this Policy is to tell you how we will collect, use and retain any personal information you provide to us.

What the law says:

Under data protection law, we can only use your personal information if we have a lawful reason to do so. We must have one or more of the following lawful reasons:

  • We have your consent;
  • We are entering into or are performing a contract with you;
  • It is in our legitimate interests;
  • When we are under a legal duty.

When we rely on our legitimate interests we mean our:

  • pursuit of our commercial activities and objectives, or those of a third party;
  • compliance with applicable legal and regulatory obligations and any codes of conduct;
  • improvement and development of our business operations and service offering, or those of a third party; or
  • protection of our business, shareholders, employees and customers, or those of a third party.

What is personal information?

Personal information is information about you and other individuals. It is information which identifies you such as your name, address and email address.

Before providing us with personal information about someone else (such as the name and email address of an additional cardholder if you are applying for a credit card with us), please tell that individual about this Privacy Policy and ask for their permission to share their personal information with us.

Who is responsible for the personal information we collect?

Madison CF UK Limited is the data controller for the purposes of the GDPR. This is because we dictate the purpose for which your personal information is used and any personal information you give us about other individuals.

How we collect and use your personal information:

You do not have to give us any personal information in order to use most of our website (www.118118money.com).

In some circumstances we may need to collect your personal information for example, by law or to perform a contract with you.  If you decide not to give us your personal information, we may not be able to fulfill our obligations.  It may also prevent us from providing you with our products and services and it may mean that we need to cancel your products and services with us.

If you are 18 or over and you wish to apply for one of our product(s), then we will need to collect certain information from you. References to you in this Policy mean you as the account holder, plus any additional cardholder that you request to be added to your account (if you hold a credit card account with us).

We have set out our reasons for using your personal information in the table below under the heading Legal Basis.  Where we rely on our legitimate interests, we have set out those interests in the table below.

You have the right to object to our use of your personal information at any time.  A summary of your right to object and details of who to contact if you want to exercise this right can be found at the Contacting us section below.

For further information on your rights please see the Your Rights section below.

Purpose

Legal Basis

To communicate with you and other individuals:

Ø  In applications, emails, SMS and letters, meetings and telephone calls (which we may record and/or monitor for quality checks and staff training);

Ø  Please note that these recordings may also be used to help us combat fraud, when registering for our products and services, in customer surveys, when you participate in competitions and promotions, through our Group company websites, and during financial reviews and interviews;

Ø  To tell you about other products or services we can offer you;

Ø  Administer offers, competitions, rewards and promotions.

Consent, performance of a contract we have with you and legitimate interests: we require your personal information in order for you to apply for and receive our products and services.

 

To make decisions about your application.

We will:

Ø  Verify your identity (and the identity of any additional cardholder you request) when you apply for or access our products and services. We may ask you to provide physical forms of identification when you apply for a product or service with us;

Ø  Check your eligibility when you apply for our products or services;

Ø  Check and analyse your income and spending habits – our checks may also include checking anyone who is financially linked to you;

Ø  Process your application (or to make counter offers or proposals) and provide services in relation to this website, including allowing you to monitor your account and repayments.

Legitimate
interests
: we require your personal information in order to enable us to assess and process your application for our products and services.

To assist in the ongoing administration of your products and services in accordance with our terms and conditions which if entered into, will be a contract between us.

Ø  Tell you about important changes or developments to the features and operation of your products and services;

Ø  Undertake financial reviews;

Ø  Trace your whereabouts and recover any debt you owe.

Performance of a contract we have with you.

For audit and statistical purposes:

Ø  For example, the amount frequency, location, origin, and recipient of your payments and other transactions, and your use of our products and services.

Ø  Gather management information to form statistical, modelling and trend analysis with the aim of developing and improving our products and services.

Legitimate interests: we require your personal information in order to enable us to assess and process your application for our products and services.

For assessment of affordability and debt recovery purposes. 

We will use information we receive from our business partners, and from other organisations such as Credit Reference Agencies (CRAs).

 

Legitimate interests: we require your personal information to enable us to process your application to enable us to provide our products and services. 

To comply with legal and regulatory obligations for example fraud prevention.

We will:

Ø  Administer, update, consolidate, improve and manage the accuracy of our records and our business including but not limited to meeting legal, regulatory and compliance requirements and operating rules (such as anti-money laundering, regulatory reporting requirements and record maintenance).

Ø  Monitor and analyse the use of any account to detect, prevent, investigate, prosecute and/or report fraud, terrorism, misrepresentation, security incidents or crime.

We will also use information we receive from fraud prevention agencies.

Necessary for compliance with a legal obligation to which we are subject.

Any information we can gather on any publicly available social media websites including Facebook, Twitter and LinkedIn.

We use this information to help manage your account by reviewing your spending habits. We also use it to help collect and recover any money that you may owe to us and to prevent fraud.

Performance of a contract we have with you and legitimate interests.

To investigate and respond to any complaints, feedback and queries.

Legitimate interests: to enable us to deal with any issues you may have in relation to our products and services.

If you download our mobile application(s) or use our website, we may collect information about your use of them including, where available:

Ø  your IP address;

 

Ø  operating system and browser type;

 

Ø  the type of device(s) you use (we use this information for system administration, fraud prevention and product development).

Performance of a contract we have with you and our legitimate interests to enable you to receive our products and services in certain formats.

 

Your personal information will be held securely so that we and any other companies in our Group that you have dealings with, either now or in the future, can manage your relationship with us. This will include information you provide when you apply to us, and any additional information provided by you or others.

What is Quick Check?

Quick Check is an online service we offer which will tell you if you might be eligible for one of our products and services (such as a loan or a credit card) without it affecting your credit rating.

If you wish to use Quick Check you will be asked to submit certain personal information to us – please see the Using credit reference agencies (CRAs) section below for further details of the information you will be asked to provide. 

Quick Check allows us to check your credit record (you’ll be able to see our search on your credit file, but other organisations won’t be able to see it which means that it will not impact your credit rating). We will use our search, together with the information you have provided to tell you if we’re likely to accept you for our products and services, solely on a credit basis using our own credit scoring methods.

Following the Quick Check, we’ll tell you if you’re likely to be accepted by us for our products and services , but this is not an offer of credit.

If, following the Quick Check, you decide to complete your application for our products and services we will run further checks (including a credit check which other organisations will be able to see on your credit file) and, if:

  • we find certain information on fraud prevention databases or we can’t verify your identity or other information you’ve given us; or
  • based on the information you’ve given us we don’t believe that the product or service is affordable or sustainable for you,
  • we will not be able to offer you the product or service.

As we are a finance broker (as well as being a lender), if we are not able to offer you one of our products or services, we may, with your consent, pass your information to Monevo Limited (Monevo). Monevo is a consumer credit lending platform who may use your information to assist you in a finding an alternative appropriate product which meets your needs.

For further information on Monevo, please visit www.monevo.com.

Who do we share your personal information with?

Our Group companies

By sharing your personal information it enables us, and other companies within our Group, and our service providers and agents to better understand your needs and run your accounts in the efficient way that you expect. We will always treat your personal information as private and confidential.

Credit reference agencies

As part of our checks in respect of your application for one of our products and services, we may also ask you to supply your bank statements in order to verify your identity and/or to verify details of your income and expenditure.

If we ask you for your bank statements, we will tell you how to supply these securely to us directly or we may offer you the option to supply them to us using MOGObankconnect (which is a free of charge service offered by CallCredit (a CRA) which enables us to see the transactions on your bank account securely).

For more information on this service, please see www.callcredit.co.uk/consumer-solutions/mogo-bank-connect.

For further information on the CRAs we use, please see the sections on Credit Scoring and Credit Reference Agencies below.

Fraud prevention agencies

We will also need to confirm your identify before we can provide you with our products and services and will need to share your personal information to help detect fraud and money laundering risks. We use fraud prevention agencies to help us with this.

Should fraud or money laundering be suspected, we will pass your personal information to a law enforcement agency so that they can investigate, prosecute and prevent financial crime. A fraud prevention agency may also share your personal information with a law enforcement agency.

Our other service providers and agents

We will share your personal information with:

  • third parties involved in managing accounts and services for you or collecting what you owe to us;
  • our suppliers of underwriting and analysis services;
  • IT service providers including those which provide our website and mobile app hosting and maintenance services;
  • sanction screening, identity and fraud prevention check providers;
  • our call centre operators;
  • business process outsourcing providers;
  • HM Revenue & Customs or other authorities;
  • third parties where we are required to do so by law (for example, we are required to screen applications that are made to us to ensure we are complying with the international fight against terrorism and other criminal activities) or by our regulatory bodies such as the Financial Conduct Authority or if we require or are required by others to investigate or prevent crime;
  • market research companies to assist in providing better products and services for you;
  • third parties who may be connected with your accounts; and
  • where we are required as part of our duty to protect your accounts, for example, we are required to disclose your information to the UK Financial Services Compensation Scheme (FSCS).

We will also share your personal information:

  • with any person to whom we sell, merge or transfer (or enter into negotiations to sell, merge or transfer) our business or part or all of our business or assets or enter into a merger with it;
  • to a potential buyer, transferee, or merger partner or seller and their advisers so long as they agree to keep it confidential and to use it only to consider the possible transaction;
  • if the transaction goes ahead, the buyers, transferee or merger partner may use or disclose your personal information in the same way as set out in this Privacy Policy.

We will always ensure your information remains safe and secure.

Why we may process special categories/sensitive personal information about you:

Some personal information under data protection law has special protection. This information is known as special categories of personal information but it may also be called sensitive personal information.  This type of personal information includes information which relates to your racial or ethnic origin, political opinions, religious beliefs or philosophical beliefs, trade union membership, genetic or biometric data or data concerning your health, sex life or sexual orientation.

When you apply to us for our products and services and, as part of managing any products and services you have with us, we may ask you for special categories of personal information.  We will only use this information to provide the service you require or help to manage your products and services and/or your account.

If we need to obtain special categories of personal information, we will ask for your explicit consent first.

Where will we transfer your personal information?

There will be times when we share your personal information within our Group and with our third party providers who are located in countries outside of the European Economic Area (EEA).

Your personal information will be transferred to countries outside the EEA such as the USA and the Philippines.  For example, if you’ve got a loan or credit card with us, we use our call centre in the Philippines for customer service calls, payment reminder calls, payment collections calls and to obtain outstanding documentation from our loan customers.

When we transfer your personal information outside the EEA, we will take reasonable steps to ensure that your personal information is protected. To do this we use a set of standard data protection clauses which have been approved by the European Commission.

The above approach is compliant with data protection law (being Article 46.2 of the GDPR). For further information about these transfers and the safeguards in place, please get in touch via the Contacting us section below.

How we use your personal information to make automated decisions:

When you apply for our products and services, we use both a manual and an automated system known as credit scoring to determine your eligibility for them. This is a method of assessing your likely conduct of an account based on a range of data, including the conduct of previous similar accounts. Credit scoring is a system widely used by credit providers to help make fair and informed decisions on lending.

Some of these decisions do not involve human input and the systems apply pre-defined logic programming and criteria to make a decision. For example, we use information about your income, expenditure, other financial commitments and payment history. This information is analysed by automated means which uses statistical models and rule based systems to evaluate your credit worthiness, affordability and overall financial health.

Credit scoring takes into account information usually from three sources:

  • the information you provide in connection with your application;
  • information provided by searches conducted at CRAs and fraud prevention agencies; and
  • information that may already be held about you by us or companies in our Group.

A credit scoring system will consider information from these sources to make an overall assessment of your application. This assessment will extend to anyone with whom you are linked financially or other members of your household.

The information we obtain may be used:

  • to check the information you have given us;
  • debt tracing;
  • analysing your income and spending habits;
  • for the detection and prevention of fraud or money laundering;
  • the management of our service to you.

If you provide a credit or debit card as part of your application or as part of a continuous payment authority, we may also use a third party to check the validity of the sort code, account code and card number that you submit in order to prevent fraud. The information you provide us will be transferred to CRAs and fraud prevention agencies who will record details of any search whether or not your application succeeds.

The credit scoring methods used are regularly tested to ensure they remain fair, effective and unbiased. Using a credit scoring system helps us to lend responsibly.

Your rights

You have the right to challenge any automated decision with us directly.  You can ask that we do not make automated decisions about you and you can object to an automated decision and ask that a person reviews it.

If you want to know more details about your rights, please get in touch via the Contacting us section below.

Using credit reference agencies (CRAs):

CRAs collect and maintain information about consumers’ and businesses’ credit behaviour. This includes Electoral Register, fraud prevention and credit information. This will include details of previous applications and the conduct of your accounts – and public information such as County Court Judgments, decrees, and bankruptcies.

We carry out credit and identity checks when you apply for our products and services. This helps us to:

  • check the information you have given us;
  • check your identity;
  • assess your financial status;
  • analyse your spending habits and your management of your accounts with us;
  • determine your chances of being accepted for our products and services;
  • help detect and prevent fraud and money laundering;
  • identify and, where applicable, rank the most appropriate products and services for you, taking into account your personal circumstances.

We will use CRAs who will make credit searches and will pass your information to CRAs (such as Callcredit Limited and Experian Limited). We will give details of your accounts and how you manage it/them to CRAs. We will also do this on a periodic basis to manage your accounts with us.

The CRA will supply us with both public (including the Electoral Register) and shared credit and fraud prevention information. This information may be supplied to other organisations by CRAs and fraud prevention agencies to perform similar checks and to trace your whereabouts and recover debts that you owe. We may also ask CRAs to give us information about you.

The CRAs will keep a record of this search and place a “footprint” on your credit file, whether or not the application proceeds.

This information may be supplied to other organisations by CRAs and fraud prevention agencies to perform similar checks and to trace your whereabouts and recover debts that you owe. We may also ask CRAs to give us information about you.

The information we provide CRAs together with any information you provided us to assess your application may be shared between us, the CRAs and fraud prevention agencies and used by them and us to make decisions, for example when:

  • checking details on applications made by you;
  • managing your accounts;
  • recovering debt;
  • checking details of job applicants and employees;
  • detect and prevent crime, fraud and money laundering;
  • check your credit history;
  • analyse your income;
  • assess your spending habits;
  • verify your identity if you apply, or someone financially linked with you applies, for products or services;
  • trace your whereabouts;
  • undertake research, statistical analysis and systems testing;
  • manage your accounts, for example, in the event that we are considering, or you ask us to consider, changing your credit limit;
  • to see if you might be eligible for any of our other products and services.

Your rights

You have the right to apply to the CRAs for a copy of your credit file.

We use different agencies so please be aware that the information they hold may not be the same. There is a small fee that you may need to pay to each agency that you apply to.

The addresses of the CRAs we currently use are:

Experian Consumer Help Service, PO Box 9000, Nottingham NG80 7WP or call 0844 481 8000 or log on to www.experian.co.uk

Callcredit Consumer Services Team, PO Box 491, Leeds LS3 1WZ or call 0870 060 1414 or log on to www.callcredit.co.uk.

You can also find out more information about the CRAs we use by reading the Credit Reference Agency Information Notice each CRA makes available on its website (see www.experian.co.uk and www.callcredit.co.uk). This notice will:

  • tell you about the CRA;
  • provide further details on the information held by the CRA and how they use it;
  • let you know who the CRA shares information with and why;
  • explain how the CRA works with fraud prevention agencies;
  • give you information on your rights.

Using Fraud Prevention Agencies:

As part of our due diligence when assessing your application, we have systems that protect our customers and ourselves against fraud and other crime.

Customer information can be used to prevent crime and trace those responsible. We will share your personal information from your application with fraud prevention agencies.

If false or inaccurate information is provided and fraud is identified, details of this fraud will be passed to these agencies. We and other organisations may access and use from other countries the information recorded by fraud prevention agencies. Law enforcement agencies may access and use this 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 accounts or facilities;
  • recovering debt;
  • checking details on proposals and claims for all types of insurance; and
  • checking details of job applicants and employees.

We may also make periodic searches at fraud prevention agencies to manage your account with us.

The Fraud Prevention Agency we use is:

Using debt collection agencies

We may refer the collection of your debt with us to a third party, to enable us to do this we will send them your personal data, along with the financial standing of your account and advise of any missed payments, and/or balances outstanding.

They will represent us in collection of the debt you owe and will not share your data with any further third parties and protect your data in the same technical manners as would 118 118 Money.

Our debt collection agencies are Moorcroft and Robinson Way.

There may be circumstances where your debt is returned to 118 118 Money and the third party debt collection agency may contain your personal data for 12 months from the date the debt is returned. The purpose for this is to ensure that any queries by you or 118 118 Money can be adequately responded. All other data retention is as per this statement.

Retention of your personal information

How long we keep your information for depends on the basis on which it was provided.

Generally, however, we will keep the information that is necessary to enable us to provide you with the products or services you have requested through our website for as long as it takes us to provide that product or service.

If you have asked that we do not use your details for marketing purposes, we may still need to keep them to ensure our systems reflect your preferences.

We will keep records of any transactions you enter into on this website for a minimum of 6.5 years from the end of our relationship with you. This is so that we can respond to any complaints or disputes that arise in that period.

We will not keep any personal information about you once you no longer have an account with us (e.g., when you no longer have a credit card or loan with us) unless we need to retain your personal information in accordance with applicable statutory requirements and any relevant industry guidelines.

If you would like to know more about how long we hold your personal information please get in touch using the Contacting us section below.

Your rights

You have certain rights with respect to your personal information.  The rights will only apply in certain circumstances and are subject to certain exemptions.

Full details of the information we store relating to you and your relationship with 118 118 Money is held in the Customer Data Protection Statement section, please choose whether you are a loan or credit card customer.

Please see the table below for a summary of your rights and who to contact to exercise them.

Your rights

What this means

Who to contact

Right of access to your personal
information

You have the right to receive a copy of your personal information that we hold about you, subject to certain exemptions. 

Write to us at:

The Data Protection Officer
Madison CF UK Limited, Fusion Point, Dumballs Road, Cardiff CF10 5BF

Email:

dpo@118118money.com

Right to rectify your personal information

You have the right to ask us to correct your personal information that we hold where it is incorrect or incomplete.

dpo@118118money.com

Right to erasure of your personal information

You have the right to ask that your personal information be deleted in certain circumstances.  For example:

Ø  where your personal information is no longer necessary for the purpose(s) it was collected or otherwise used;

Ø  if you withdraw your consent and there is no other legal reason to permit us to continue to use your personal information;

Ø  if you object to the use of your personal information (see below);

Ø  if we have used your personal information unlawfully; or

Ø  if your personal information needs to be erased to comply with a legal obligation.

dpo@118118money.com

Right to restrict the use of your
personal information

You have the right to suspend our use of your personal information in certain circumstances.  For example:

Ø  where you think your personal information is inaccurate;

Ø  the use of your personal information is unlawful but you don’t want us to delete it;

Ø  we no longer need your personal information, but your personal information is required by you for the establishment, exercise or defence of legal claims; or

Ø  you have objected to the use of your personal information and we are verifying whether our grounds for the use of your personal information override your objection.

dpo@118118money.com

Right to data portability

You have the right to obtain your personal information in a structured, commonly used and machine-readable format and for it to be transferred to another organisation, where it is technically feasible.

This right only applies where the use of your personal information is based on your consent or for the performance of a contract, and when the use of your personal information is carried out by automated (i.e. electronic) means.

dpo@118118money.com

Right to object to the use of your personal information

You have the right to object to the use of your personal information in certain circumstances. For example:

Ø  where you have grounds relating to your particular situation and we use your personal information for our legitimate interests (or those of a third party); and

Ø  if you object to the use of your personal information for direct marketing purposes.

Write to us at:

The Data Protection Officer
Madison CF UK Limited, Fusion Point, Dumballs Road, Cardiff CF10 5BF

Email:

dpo@118118money.com

Right to withdraw consent

You have the right to withdraw your consent at any time where we rely on consent to use your personal information.

Write to us at:

The Data Protection Officer
Madison CF UK Limited, Fusion Point, Dumballs Road, Cardiff CF10 5BF

Email:

dpo@118118money.com

Right to complain to the relevant data protection authority

You have the right to complain to the Information Commissioner’s Office (ICO), where you think we have not used your personal information in accordance with data protection law.

Contact the ICO:

v  ICO Telephone:  0303 123 1113

 

v  ICO website: www.ico.org.uk

Links to third party websites:

Our website (www.118118money.com) contains links to other websites over which we have no control.

We are not responsible for privacy policies or practices of other websites to which you choose to link from our website. We encourage you to review the privacy policies of those other websites so you can understand how they collect, use and share your information.

Marketing:

If you opted to receive newsletters, commercial emails or other communications from us or selected third parties at the time you applied to see if you were eligible for a product from us but subsequently change your mind, you may opt-out by Contacting us as set out at the end of this Privacy Policy.

Cookies:

We use cookies on our website (www.118118money.com) to distinguish you from other users of the website.  This helps us
to provide you with a good experience when you browse the Website and also allows us to improve the Website.

For information on the cookies we use and the purposes for which we use them, please see our Cookie Policy.

Data Protection Statement

 

FOR LOANS PRODUCTS

 

CUSTOMERS OF 118 118 MONEY

Type of Data

Why do we need this information?

Source of data

Where stored?

Shared externally?

Retained for?

PERSONAL DATA COLLECTED FROM YOU DURING
LOAN AND CREDIT CARD APPLICATION PROCESS (INC. QUICK CHECK PROCESS)

Name
(including Title, First name and Surname)

Identification during application process

 

ID verification if you call us

You

Ireland
& UK

Loan management system  

Yes

Passed to credit reference agencies
(Callcredit:
https://www.callcredit.co.uk/crain)

See
application decision for retention periods

Email
address

Contact during application process

No

Mobile
number

Contact during application process

Date
of birth

Identification during application process

 

ID verification if you call us

Yes

Passed to
credit reference agencies
(Callcredit: https://www.callcredit.co.uk/crain)

Employer

Identification during application process

No

Net
monthly income

Affordability checks during application
process

Monthly
outgoings

Affordability checks during application
process

Address
including postcode

Identification during application process

 

ID verification if you call us

Yes

Passed to
credit reference agencies
(Callcredit: https://www.callcredit.co.uk/crain)

Time
at address

Identification during application process

Yes

Passed to
credit reference agencies
(Callcredit: https://www.callcredit.co.uk/crain)

Bank
details

Identification
during application process

No





 

Nationality
or confirmation of being UK citizen

We can
only provide service to UK citizens or those with right to reside in the UK

Debit
card Details

Identification
during application process


We may also receive the above information from a third party such as a comparison web-site. Should
you choose not to submit the application once you have the option to complete on our site, then we may
retain your application personal data as if you had been declined or had chosen not to continue with the
loan.


Type of Data

Why do we need this information?

Source of data

Where stored?

Shared externally?

Retained for?

 

IF YOU ARE REFERRED TO OUR UNDERWRITING TEAM

(IN ADDITION TO THE APPLICATION PERSONAL DATA)

CallCredit

(CallValidate)

Check validity of bank account

CallCredit

Ireland
& UK

Loan management system  

No

See
application decision for retention periods

CallCredit

(Credit
Search)

Assessment of current and previous
lending

Ireland
& UK

Loan management system  

CallCredit

(TAC)

Affordability checks as required by FCA

Ireland
& UK

Loan management system  

Bank
statements

 Affordability
checks as required by FCA

You

Ireland
& UK

Loan management system  

Photo
identification

Identification verification

Ireland
& UK

Loan management system  

Right
to reside

We can only provide service to UK
citizens or those with right to reside in the UK

Ireland
& UK

Loan management system  

REPORTING OF POTENTIALLY FRAUDULENT LOAN
APPLICATIONS

Personal
information provided by you during the loan application process

To CIFAS for reporting potential
fraudulent activity

Loan Manage-ment System  

Ireland
& UK

Loan management system  

Yes

CIFAS

6 years from date uploaded

Loan
application date

APPLICATION DECISION – IF YOU ARE AUTOMATICALLY DECLINED OR WE HAVE ASSESSED YOUR APPLICATION AS NOT BEING ELIGIBLE/YOU CHOOSE NOT TO PROCEED WITH YOUR LOAN APPLICATION/YOU WITHDRAW FROM THE AGREEMENT

CallValidate

Check validity of bank account

CallCredit

Ireland
& UK

Loan management system  

No

 

24 months

 

Credit
Search

Assessment of current and previous
lending

Ireland
& UK

Loan management system  

TAC

Affordability checks

Ireland
& UK

Loan management system  

All
personal information provided by you during application

To refine our scoring procedures

You

(with permission to re-use)

UK

Loan declines database

Yes

Passed to
credit reference agency
(Callcredit:
https://www.callcredit.co.uk/crain) maximum
twice within 24 months



APPLICATION DECISION – APPROVED FOR A LOAN

 



Type of Data

Why do we need this information?

Source of data

Where stored?

Shared externally?

Retained for?

Agreement
number

For loan products, you are assigned a
unique reference number.

This may be used as a pseudonymised way
of referring to your account with us.

System generated

Ireland
& UK

Loan management system  

No

End
of product term + 6 years and 6 months

 

CallValidate

Check validity of bank account

CallCredit

 

Ireland
& UK

Loan management system  

 

Credit
Search

Assessment of current and previous
lending

 

TAC

Affordability checks

 

Credit
score

Score indicating credit worthiness

 

 

IF YOU ARE IN ARREARS, WE MAY RECEIVE THIS
INFORMATION FROM A THIRD PARTY

 

Type of Data

Why do we need this
information?

Source of data

Where stored?

Shared externally?

Retained for?

 

Financial Statement

Assessment of ability to
repay your debt

Debt Manage-ment Company

 

Insolvency Practitioner

Ireland & UK

Loan management system  

 

Collections task system

 

Internal Network Drive

 

Yes

Financial Ombudsman (where appropriate)

 

Financial Conduct Authority (where appropriate)

 

End
of product term + 6 years and 6 months

 

List of other creditors including reference numbers

Assessment of ability to
repay your debt

 

Motor Vehicle details

Assessment of ability to
repay your debt

 

Personal information of Partner/Family members

Assessment of ability to
repay your debt

Debt Manage-ment Company

 

Insolvency Practitioner

 

Age of dependent

Assessment of ability to
repay your debt

 

Debt Manage-ment Company

 

Insolvency Practitioner

Ireland & UK

Loan management system  

 

Collections task system

 

Internal Network Drive

Yes

Financial Ombudsman (where appropriate)

 

Financial Conduct Authority (where appropriate)

End
of product term + 6 years and 6 months

 

Total Liabilities

 

Asset information including values

 

Estimated Deficiencies

 

Customer Circumstances

 

Medical professional information including Name and
address.

Assessment of ability to
repay your debt

Medical Professional

 

Medical History

End
of product term + 6 years and 6 months

MARKETING MESSAGES (WHERE YOU HAVE OPTED IN)

 



Type of Data

Why do we need this information?

Source of data

Where stored?

Shared externally?

Retained for?

Name

For sending personalized marketing
messages based on the preferences you have stated and your interest in our
products

 

You

Ireland
& UK

Customer Relationship Management system

No

Until
you opt out of receiving marketing messages

 

Address
including postcode

 

Mobile
number

 

Email
address

 

You are able to manage your marketing preferences by logging into your user portal, via the mobile app or by calling our Customer Services team.

The default setting for marketing is opt-out by all methods.

The above may be shared with selected third parties in circumstances where you have provided permission for this.

Under GDPR (General Data Protection Regulation), you have the right to:

1.            Right to be informed of why, how and where we process your personal data

This statement meets this requirement, advising you on what data we collect, who we may share it with and how long we may store it for.

2.            Right to access your data

To access the data we keep on you, please email your subject access request to dpo@118118money.com. Please provide as much scope and timelines as possible to assist us in retrieving your data as quickly as possible.

3.            Right to have your data corrected/updated

The data we keep on you should always be up-to-date and relevant, if you require changes to the data, then please contact your local representative of the department which holds your data, this information can be found in the table above.

4.            Right to have your data deleted (right to erasure)

Please contact dpo@118118money.com to have your data deleted, please state what data and why.

5.            Right to restrict processing, enabling 118 118 Money to store the data but no longer process it

Should you require us not to process your information as described in the table, please contact the information holder or the data protection officer (dpo@118118money.com) immediately and request it to be restricted.

6.            Right to data portability

If you need us to port your data elsewhere, please contact data protection officer (dpo@118118money.com) with full details of your requirements.

7.            Right to object

You have the right to object or opt out of processing based on performance of the process and or direct marketing or profiling.  To object, please contact Customer Services on 08000 118 000 or you can escalate your concerns to the Information Commissioner by completing the form on https://ico.org.uk/concerns/handling/

8.            Rights related to automated decision making and profiling

118 118 Money will use automated decisioning when considering your eligibility for one of our financial services products.  You are able to contact us via our Customer Services lines (as shown above) to discuss the outcome of our assessment.


Data Protection Statement

 

CREDIT CARD CUSTOMERS – 118 118 MONEY

 

Type of Data

Why do we need this information?

Source of data

Where stored?

Shared with another company?

Retained for?

WHEN APPLYING FOR A CREDIT CARD ON OUR
WEB SITE OR VIA A MOBILE APP

Name
(including Title, First name and Surname)

Identification during application process

 

ID verification if you call us

 

Checking for duplicate applications
(potential fraud)

 

You

Ireland
& UK

Internal credit card customer databases

Yes

CallCredit

Experian

(credit
reference and scoring)

(Callcredit: https://www.callcredit.co.uk/crain)

See
application decision for retention periods

Email
address

Contact during application process

 

Checking for duplicate applications
(potential fraud)

Mobile
number

Date
of birth

Identification during application process

 

ID verification if you call us

 

Checking for duplicate applications
(potential fraud)

Employer

Identification during application process

 

Checking for duplicate applications
(potential fraud)

Net
monthly income

Affordability checks during application
process

Monthly
outgoings

Affordability checks during application
process

Address
including postcode

Identification during application process

 

ID verification if you call us

Ireland
& UK

Internal credit card customer databases

Time
at address

Identification during application process

Residential
Status

Identification during application process

Type of Data

Why do we need this information?

Source of data

Where stored?

Shared with another company?

Retained for?

Marital
Status

Identification during application process

You

Ireland
& UK

Internal credit card customer databases

Yes

CallCredit

Experian (Callcredit: https://www.callcredit.co.uk/crain)

(credit
reference and scoring)

See
application decision for retention periods

 

CREDIT CARD APPLICATION IS APPROVED

 

Type of Data

Why do we need this information?

Source of data

Where stored?

Shared with another company?

Retained for?

WHEN CREDIT CARD APPLICATION IS
APPROVED

Name
(including title, first name and surname)

ID verification if you call us

You

Third
Party – UK

TSYS (credit card management)

 

Ireland
& UK

118 118 Money database records

Yes

TSYS (credit card
management)

 

TMS (customer
services, fraud, collections)

 

Idemia (printing of
plastics, card mailers, PIN mailers)

 

RR Donnelly (management of
outgoing mail and statements)

 

6 years, 6
months from the termination of your credit card agreement with us

Email
address

Yes

TSYS (credit card
management)

 

TMS (customer
services, fraud, collections)

 

Mobile
number

Date
of birth

Address
including postcode

Yes

TSYS (credit card
management)

 

TMS (customer
services, fraud, collections)

 

Idemia (printing of
plastics, card mailers, PIN mailers)

 

RR Donnelly (management of
outgoing mail and statements)

 

Name
(as shown on credit card)

To print plastic card showing your name

 

To answer your questions through customer
services, fraud investigations or collections team.

 

To send you regular service-related mail
and monthly statements

You

Third
Party – UK

TSYS (credit card management)

Yes

TSYS (credit card
management)

 

TMS (customer
services, fraud, collections)

 

Idemia (printing of
plastics, card mailers, PIN mailers)

6 years, 6
months from the termination of your credit card agreement with us

Primary
Account Number (PAN – 16 digit credit card number)

To refer to your account along with your
name, address and other personal data

 

Printing on your credit card

 

Used as a reference in reporting within
118 118 Money

Third
Party

TSYS (Credit card management)

 

Originating
from Mastercard

Third
Party – UK

TSYS (credit card management)

Yes

TSYS (credit card
management)

 

TMS (customer
services, fraud, collections)

 

Idemia (printing of
plastics, card mailers, PIN mailers)

Bank
details

Identification
during application process

 

For taking
regular payments

You

Third
Party

TSYS (credit card management)

Yes

TSYS (credit card
management)

 

TMS (customer
services, fraud, collections)


REPORTING OF POTENTIALLY FRAUDULENT LOAN APPLICATIONS

 



Type of Data

Why do we need this information?

Source of data

Where stored?

Shared externally?

Retained for?

Personal
information provided by you during the loan application process

To CIFAS for reporting potential
fraudulent activity

Third
Party

TSYS (Credit card management)

Third
Party – UK

TSYS (Credit card management)

Yes

CIFAS

6 years from date uploaded

 

Credit
card application date

 

MARKETING MESSAGES (WHERE YOU HAVE OPTED IN)

 



Type of Data

Why do we need this information?

Source of data

Where stored?

Shared externally?

Retained for?

Name

For sending personalized marketing
messages based on the preferences you have stated and your interest in our
products

 

You

Ireland
& UK

Customer Relationship Management system

No

Until
you opt out of receiving marketing messages

 

Address
including postcode

 

Mobile
number

 

Email
address

 

 

You are able to manage your marketing preferences by logging into your user portal, via the mobile app or by calling our Customer Services team.

The default setting for marketing is opt-out by all methods.

The above may be shared with selected third parties in circumstances where you have provided permission for this.

IF YOU CHOOSE TO ADD AN ADDITIONAL CARDHOLDER


Type of Data

Why do we need this information?

Source of data

Where stored?

Shared with another company?

Retained for?

IF YOU CHOOSE TO ADD AN ADDITIONAL
CARDHOLDER

 

Name
of additional cardholder (as shown on credit card)

To print plastic card showing their name

 

Identification when you contact us

You

Third
Party

TSYS (credit card management)

Yes

TSYS (credit card
management)

 

TMS (customer
services, fraud, collections)

 

Idemia (printing of
plastics, card mailers, PIN mailers)

6 years, 6
months from the termination of the main account holder’s credit card
agreement with us

Name
(including Title, First name and Surname) of additional cardholder

To register details

You

(we assume that you have permission from
the additional cardholder to use their personal information)

Third
Party

TSYS (credit card management)

Yes

TSYS (credit card
management)

 

TMS (customer
services, fraud, collections)

 



Type of Data

Why do we need this information?

Source of data

Where stored?

Shared with another company?

Retained for?

Date
of birth of additional cardholder

To ensure that the additional cardholder
is over the age of 18

You

(we assume that you have permission from
the additional cardholder to use their personal information)

Third
Party

TSYS (credit card management)

 

 

Address
of additional cardholder ( including postcode)

Requirement is that the additional
cardholder lives at the same address as the main cardholder

You

(we assume that you have permission from
the additional cardholder to use their personal information)

Third
Party

TSYS (credit card management)

Mobile
number of additional cardholder

For providing service messages relating
to the additional cardholder

 

Identification when you contact us

You

(we assume that you have permission from
the additional cardholder to use their personal information)

Third
Party

TSYS (credit card management)

Relationship
to main cardholder

Terms and conditions require additional
cardholder to be a family member

You

(we assume that you have permission from
the additional cardholder to use their personal information)

Third
Party

TSYS (credit card management)

Yes

TSYS (credit card
management)

 

TMS (customer
services, fraud, collections)

 

6 years, 6 months from the termination of
the main account holder’s credit card agreement with us

Primary
Account Number (PAN – 16 digit credit card number)

To refer to your account along with your
name, address and other personal data

 

Printing on your credit card

 

Used as a reference in reporting within
118 118 Money

Third Party

TSYS (Credit card management)

 

Originating from Mastercard

Third
Party

TSYS
(credit card management)

Yes

TSYS (credit card
management)

 

TMS (customer
services, fraud, collections)

 

Idemia (printing of
plastics, card mailers, PIN mailers)

 

CREDIT CARD APPLICATION IS DECLINED/NOT TAKEN UP/WITHDRAWN

Analytics and Scoring Procedures

118 118 Money may retain your personal data if you are declined as a credit card customer for the purpose of improving the scorecards for our financial services products.

The legitimate interest requirement is to enable us to further refine our scoring based on the information submitted as part of the application process.   This applies to both declined and approved customers.  This information may be passed to relevant third parties (such as Credit Reference Agencies) to assist us in building better models for credit scoring in the future.

This information is retained for declined applications for 24 months.

MARKETING MESSAGES (WHERE YOU HAVE OPTED IN)

 



Type of Data

Why do we need this information?

Source of data

Where stored?

Shared externally?

Retained for?

Name

For sending personalized marketing
messages based on the preferences you have stated and your interest in our
products

 

You

Ireland
& UK

Customer Relationship Management system

No

Until
you opt out of receiving marketing messages

 

Address
including postcode

 

Mobile
number

 

Email
address

 

You are able to manage your marketing preferences by logging into your user portal, via the mobile app or by calling our Customer Services team.

The default setting for marketing is opt-out by all methods.

The above may be shared with selected third parties in circumstances where you have provided permission for this.

Under GDPR (General Data Protection Regulation), you have the right to:

1.            Right to be informed of why, how and where we process your personal data

This statement meets this requirement, advising you on what data we collect, who we may share it with and how long we may store it for.

2.            Right to access your data

To access the data we keep on you, please email your subject access request to dpo@118118money.com. Please provide as much scope and timelines as possible to assist us in retrieving your data as quickly as possible.

3.            Right to have your data corrected/updated

The data we keep on you should always be up-to-date and relevant, if you require changes to the data, then please contact your local representative of the department which holds your data, this information can be found in the table above.

4.            Right to have your data deleted (right to erasure)

Please contact dpo@118118money.com to have your data deleted, please state what data and why.

5.            Right to restrict processing, enabling 118 118 Money to store the data but no longer process it

Should you require us not to process your information as described in the table, please contact the information holder or the data protection officer (dpo@118118money.com) immediately and request it to be restricted.

6.            Right to data portability

If you need us to port your data elsewhere, please contact data protection officer (dpo@118118money.com) with full details of your requirements.

7.            Right to object

You have the right to object or opt out of processing based on performance of the process and or direct marketing or profiling.  To object, please contact Customer Services on 08000 118 000 or you can escalate your concerns to the Information Commissioner by completing the form on https://ico.org.uk/concerns/handling/

8.            Rights related to automated decision making and profiling

118 118 Money will use automated decisioning when considering your eligibility for one of our financial services products.  You are able to contact us via our Customer Services lines (as shown above) to discuss the outcome of our assessment.

Changes to this Privacy Policy:

If our Privacy Policy changes in any way, we will place an updated version on this page. Regularly reviewing this page ensures that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.

Where appropriate we will give you reasonable notice of any changes.

This Privacy Policy was last updated in August 2018.

Contacting us:

If you have any questions about this Policy or your personal information and/or if you wish to see what information we hold about you, please contact the Data Protection Officer on dpo@118118money.com.

If you no longer wish to receive any marketing communications or wish us to stop using  your personal information, please contact us:

By accessing your 118 118 Money customer portal. Login to your account, via a browser, and go to the Marketing Preferences section.

By phone: 08000 118 000 is free from UK landlines and mobiles. 02920 893300 is charged by your provider as UK national number.

By mail: 118 118 Money, Fusion Point, Dumballs Road, Cardiff, CF10 5BF

By email: dpo@118118money.com

How to complain:

If you think there is a problem with how your personal information is being handled, you have a right to complain to the Information Commissioner’s Office (ICO).

The ICO can be contacted on 0303 123 1113 or please visit their website at www.ico.org.uk.