1. SCOPE

This website 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 inter alia, 118 118 and Conduit Global, all together the “Group”.

118 118 Money is authorised and regulated by the Financial Conduct Authority (Interim permission number 656451). You can confirm our registration on the Financial Conduct Authority’s website www.fca.org.uk or by contacting the Financial Conduct Authority on 0800 111 6768.

We comply with data protection legislation such as the Data Protection Act 1998. This regulates the processing of personal data relating to you and grants you various rights in respect of your personal data.

The aim of this statement is to tell you how we will collect, use and retain any personal data you provide through this website. Please read it carefully before you proceed.

2. HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION

You do not have to give us any personal data in order to use most of our website. You must be at least 18 years old to apply for a loan. If you are under 18, please stop using this website.

However, if you are 18 or over and you wish to apply for a loan, then we will need to collect certain information from you. 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 in various ways, including and without limitation:

  1. In applications, emails and letters, during telephone calls and conversations which we may record and/or monitor for quality checks and staff training. Please note that these recordings may also be used to help us combat fraud, when registering for services, in customer surveys, when you participate in competitions and promotions, through our Group company websites, and during financial reviews and interviews.
  2.  For analysis (for example, the amount frequency, location, origin, and recipient) of your payments and other transactions, and your use of our services;
  3. Information we receive from our business partners, and from other organisations such as Credit Reference Agencies (“CRAs”) and fraud prevention agencies;
  4. In addition, we may collect information about your computer including, where available, your IP address, operating system and browser type – for system administration, fraud prevention and product improvement; and
  5. Any information we can gather on any publicly available social media websites including and without limitations Facebook, Twitter and LinkedIn.

The information we collect allows us to:

  • Verify your identity when you access the services on this website;
  • Analyse your income and spending habits;
  • Process your loan 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;
  • Communicate with you (including for example and without limitation, via email or SMS) and/or by responding to your enquiries and complaints;
  • Investigate any complaints about the use of the website; and
  • Tell you about other services or products we can offer you from our Group of companies or any of our external partners and notify you about either important changes or developments to the features and operation of those products and services;
      • administer offers, competitions, and promotions; and
      • undertake financial reviews.

We may also use the information to:

  • 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);
  • Monitor and analyse the use of any account to detect, prevent, investigate, prosecute and/or report fraud, terrorism, misrepresentation, security incidents or crime;
  • Trace your whereabouts and recover any debt you owe;
  • Gather management information to form statistical, modeling and trend analysis with the aim of developing and improving products and services; and
  • Share 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. If so, we may disclose your personal information 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 notice.

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

Such service providers and agents may include, without limitation, third parties who carry out underwriting and analysis, hosting, maintenance, sanction screening, identity checking, call centre operation, or provide other services in relation to this website. We may share your information with our Group and disclose it outside of our Group if:

  1. allowed by this agreement;
  2. needed by our agents, advisers or others involved in managing accounts and services for you or collecting what you owe to us;
  3. needed by contractors and/or subcontractors to help us manage your records;
  4. required by HM Revenue & Customs or other authorities;
  5. requested by law, regulatory bodies, or the public interest permits;
  6. required by us or others to investigate or prevent crime;
  7. needed by market research companies to assist us in providing better products and services for you;
  8. required by any other parties who may be connected with your accounts; and
  9. 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 always ensure your information remains safe and secure.

By applying for a loan with us, you expressly consent to your personal information being shared electronically with our external business partners for the purposes outlined herein (including without limitation CRAs, fraud prevention agencies, credit brokers, and debt collection agencies).

Your data may also be used for other purposes for which you give your specific permission, or, in very limited circumstances, when required by law or where permitted under the terms of the Data Protection Act 1998.

The government also requires us to screen applications that are made to us to ensure we are complying with the international fight against terrorism and other criminal activities. As a result of this we may need to disclose information to government bodies.

The Data Protection Act defines certain information as ‘sensitive’ (racial or ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, sexual life, criminal proceedings and offences). If you apply to us for a loan, we may ask you for some ‘sensitive’ details. We will only use this information to provide the service you require and we will ask for your explicit consent. As a customer, there may be times when you give us sensitive information. We may share it with other parts of the kgb Group and our service providers to keep your records up to date. All countries in the European Economic Area (EEA), which includes the UK, have similar standards of legal protection for your personal information. Your personal information may be transferred to the recipients identified above in countries outside the EEA (such as the USA and the Philippines) that do not have a similar standard of data protection laws to the UK. If so, we will require your personal information to be protected to at least UK standards. Those external organisations may process and store your personal information abroad and may have to disclose it to foreign authorities to help them in their fight against crime and terrorism. If these are based outside the EEA, your personal information may not be protected to standards similar to those in the UK. For example, we use our call centre in the Philippines for customer service calls, payment reminder calls, payment collections calls and to obtain outstanding documentation from customers.

If you have any questions or concerns about the sharing of your personal information as described above, please contact us as described at the end of this Privacy Policy. Depending on the nature of your request, you may have the opportunity to opt-out of these sharing practices in limited circumstances. In addition, we reserve the right to use and disclose all information that is not in individually identifiable form as we deem appropriate in our sole discretion.

A. USING CREDIT SCORING

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

Credit scoring takes into account of 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 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 for debt tracing, analysing your income and spending habits, together with the prevention of fraud or money laundering as well as the management of our service to you. If you provide a credit or debit card, we may also use a third party(ies) 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. If you submit an application and it is declined through any of these processes, you can contact us within 15 working days to have the decision reconsidered. If you provide a credit or debit card, we may also use a third party(ies) to check the validity of the sort code, account code and card number that you submit in order to prevent fraud.

B. USING CREDIT REFERENCE AGENCIES

By submitting your loan application, you are authorising us to analyse the information you provide to assess your financial status, determine your chances of being accepted for a loan and identify and, where applicable, rank the most appropriate loan products for you, taking into account your personal circumstances. In addition, you understand that we will use CRAs who will make credit searches and will pass your information to CRAs including and without limitation Callcredit Limited and Experian Limited. These agencies will record details of any search whether or not your application succeeds. The CRAs will keep a record of this search and place a “footprint” on your credit file, whether or not the application proceeds. You can access your information at www.callcredit.co.uk and www.experian.co.uk. They supply us with both public (including the electoral register) and shared credit and fraud prevention information.

You have the right to apply to the CRAs for a copy of your file. We use different agencies and be aware that the information they hold may not be the same and there is a small fee (currently, £2) that you may need to pay to each agency that you apply to. Their addresses 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.

Any and/all information may be used to assess your application, check your identity, assess your management of your income, analyse your spending habits, for debt tracing and the prevention of fraud or money laundering as well as the management of our service to you. If you provide a credit or debit card, we may also use a third party(ies) to check the validity of the sort code, account code and card number that you submit in order to prevent fraud.

Where you borrow from us, we will give details of your accounts and how you manage it/them to CRAs. 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.

CRAs collect and maintain information about consumers’ and businesses’ credit behaviour. This includes Electoral Register, fraud prevention, and credit information – including without limitations, details of previous applications and the conduct of your accounts – and public information such as County Court Judgments, decrees, and bankruptcies.

The information we provide CRAs together with any information you provided us to assess your application may be provided to other agencies and used by them to:

  1. Help them make decisions, for example when:
    • checking details on applications for a loan;
    • managing your loan;
    • recovering debt; and
    • checking details of job applicants and employees
  2. detect and prevent crime, fraud and money laundering;
  3. check your credit history;
  4. analyse your income;
  5. assess your spending habits;
  6. verify your identity if you apply, or someone financially linked with you applies, for products or services;
  7. trace your whereabouts; and
  8. undertake research, statistical analysis and systems testing.

If you borrow and do not repay in full and on time, we may give details of your account and how you conduct it to CRAs. If you fall behind with your payments and a full payment or a satisfactory settlement proposal is not received within 28 days of a formal demand being issued, then a default notice may be recorded with the CRAs. Any records shared with CRAs will remain on file for 6 years after your account is closed, whether it has been settled by you or as a result of a default. Other organisations may see these searches and updates if you apply for credit in the future, and these may affect your ability to borrow from other lenders. We may also make periodic searches at CRAs to manage your account with us.

C. 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 and without limitation, 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 that we use is CIFAS, with registered office at 6th Floor Lynton House, 7-12 Tavistock Square, London, WC1H 9LT. You can contact CIFAS at https://www.cifas.org.uk/contact_us.

D. HOW WE CHECK YOUR IDENTITY

In addition to the information provided on your application and the information we receive as a result of our searches with the CRAs and the fraud prevention agencies, we may ask you to provide physical forms of identification when you apply for a loan. We may ask you to provide physical forms of identity verification when you apply for a loan with us. We may also telephone to confirm your identity. You have a legal right to these details.

E. MARKETING COMMUNICATIONS

From time to time, we may wish with your agreement to contact you by email, SMS, post or phone with information about other products or services which may be of interest to you. These communications may be from us or other members of our Group or it may be from other organisations offering financial products and services or from other organisations whose products or services we think may be of interest to you. Where your application has been declined, we may with your agreement share your details with other carefully selected financial organisations that may be able to offer alternative loan arrangements. We will only transfer your personal data to third parties for marketing purposes with your express opt-in consent to do so.

3. 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 a service that you have requested through this website for as long as it takes us to provide that 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 generally keep records of any transactions you enter into on this website for a minimum of six years from the end of the relationship. This is so that we can respond to any complaints or disputes that arise in that period. Otherwise we will keep the information where appropriate for legitimate business needs.

We will keep other information about you if it is necessary for us to do so to comply with the law, or where appropriate for legitimate business needs. For applications abandoned or declined, we shall keep your information for a maximum of one year.

For any marketing purposes for which you consented to, we shall keep your information no longer than it is necessary to comply with this objective.

4. COOKIES

In general, you can visit our website without identifying who you are or revealing any information about yourself. However, cookies are used to store small amounts of information on your computer, which allows certain information from your web browser to be collected. Cookies are widely used on the internet and do not identify the individual using the computer, just the computer being used. Cookies and other similar technology make it easier for you to log on to and use our website during future visits.

To access our cookie notice, please go to www.AboutCookies.org .

To find out more about cookies please visit: www.allaboutcookies.org or see www.youronlinechoices.eu which contains further information about behavioural advertising and online privacy.

5. LINKS

Our website 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 this 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.

6. YOUR RIGHT TO ACCESS INFORMATION

You are entitled to see the information held about you.
We may require you to verify your identity and to pay an administration fee (currently, £10) to provide a copy of the information we hold. Please note that in certain circumstances we may withhold access to your information where we have the right to do so under current data protection legislation.

7. UPDATING YOUR INFORMATION

You may review, correct, update or change your personal information at any time by contacting Customer Services as set out at the end of this Privacy Policy.

If you opted to receive newsletters, commercial emails or other communications from us or selected third parties at the time you registered on this website but subsequently change your mind, you may opt-out by contacting us as set out at the end of this Privacy Policy.

8. 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. This Privacy Policy was last updated on 10 October 2014.

9. CONTACTING US

If you have any questions about this statement or your personal information and/or if you wish to see what information we hold about you, please contact the Data Protection Officer on 08000 118 000 or 02920 893300* or 118 118 Money, Fusion Point, Dumballs Road, Cardiff, CF10 5BF.

If you no longer wish to receive any marketing communications or share your details, please contact us:

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: CustomerServices@118118money.com