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 contacted 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 identify 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 asses 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  asses 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 QuickCheck?

QuickCheck 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 QuickCheck 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. 

QuickCheck 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 QuickCheck, 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 QuickCheck, 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 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 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:

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.

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.

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 April 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 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.