- Who are we?
- Data protection officer
- What personal data do we collect?
- How is your personal data used
- How is personal data used for marketing?
- Is personal data processed by automated means?
- Who do we share your personal data with?
- Credit reference and fraud prevention agencies
- What about third-party account management?
- Do we transfer your personal data outside of the uk?
- How do protect your personal data?
- How long do we keep your personal data?
- What are your rights? how do you exercise your rights?
- How are cookies used?
- How do you make a complaint?
- Contacting you
- What about changes?
1.1 We take our data protection obligations seriously. Please read this Privacy Notice carefully as it contains important information on who we are and how we use your Personal Data.
1.2 This Privacy Notice describes how we and the Lending Works Group of companies collects, uses, shares and stores Personal Data about you. This includes both Personal Data from which you can be easily and instantly identified and Personal Data from which you can be identified when used in combination with any other information. We collectively refer to this as your “Personal Data”.
1.2 We will always process any Personal Data about you in compliance with applicable data protection laws (including the retained General Data Protection Regulation (EU) 2016/679 (“UK GDPR”) and the UK Data Protection Act 2018 (“DPA”).
1.3. By submitting Personal Data to us, you acknowledge and understand that it may be processed as set out in this Privacy Notice.
1.4. If you are a borrower or prospective borrower, this Privacy Notice is supplementary to and does not replace any terms in your credit agreement about how we or the lender will collect and use your Personal Data. The relevant terms in your credit agreement will prevail when there is a conflict.
2. Who are we
2.1 The Data Controller is Lending Works, a trading name of Fluro Platform Limited. Fluro Platform Limited (8302549) (“Lending Works”, “Our”, “Us” and “We”) is authorised and regulated by the Financial Conduct Authority (723151).
2.2 Our registered office and place of business is 55 Old Broad Street, London, England EC2M 1RX.
2.3 We are registered with the Information Commissioner's Office (ZA002001).
2.4 We are a member of Cifas and Innovate Finance.
3. Data protection officer
3.1 We have appointed a Data Protection Officer.
3.2 If you have any queries about this Policy, how we process your Personal Data, or about exercising any of your rights, you may contact the Data Protection Officer using the following contact details:
Fluro Platform Limited
55 Old Broad St
London, EC2M 1RX
Telephone: 020 7096 8512
4. What personal data do we collect?
We may collect and process the following Personal Data:
4.1 Personal Data You Give Us
We may collect Personal Data from you:
- completing a form on our Website;
- entering a competition, promotion or survey;
- corresponding with us by phone, email, or in writing;
- attending an event organised by us;
- completing a course or e-learning module offered by us;
- reporting a problem;
- signing up to receive our communications;
- creating an account with us;
- entering into a contract with us to receive products and/or services;
- carrying out any other activity or transaction; or
- using our website (www.lendingworks.co.uk) or any pages arising from or connected to the stated domain, including any sub-domains, referred to as the “Website”) or on the Lending Works Platform (“Platform”).
The Personal Data you give us may include your name, address, date of birth, income, email address, phone number, financial and credit/debit card information, transaction details, personal description and business information, and any photographs.
4.2 Personal Data From Other Sources
If you visit our Website, we may automatically collect the following Personal Data and/or information:- technical information, including the internet protocol (IP) address used to connect your computer to the Internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- Full Uniform Resource Locators (URLs) to, through and from our Website (including date and time); products you viewed or searched for;
- page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs);
- methods used to browse away from the page and any phone number used to call our customer service number; and
Some devices allow applications to access real-time location-based Personal Data (for example GPS). If you access our Website or Platform from any such devices, we may collect such Personal Data from your mobile device at any time while you download or use our Website or Platform. We may use this Personal Data to optimise your experience and to help us prevent and detect fraud.
4.3. Personal Data About Other People
If you give us Personal Data on behalf of someone else, you confirm that you have given them the information set out in this Privacy Notice you must ensure that they understand how their Personal Data will be processed, and that they have given their permission for you to disclose it to us and for you to allow us, and our third-party service providers, to process it.
We may receive Personal Data about you from:
- our business partners and affiliates;
- our payment service providers and our bank(s);
- credit reference agencies; and
- fraud prevention agencies.
We may also receive Personal Data about you if you use any of the other websites which we, or another member of the Lending Works Group, operate or the other services and/or products which we, or another member of the Lending Works Group, provide.
4.4. Special Category Data
In exceptional circumstances, we may also collect and/or be provided with special category data, such as data about your physical or mental health or condition. For example, we may collect and/or be provided with special category data to enable us to administer requests for reasonable adjustments, or in relation to an investigation, complaint, or appeal. Such data should only be collected and/or provided to us if you have provided your explicit consent or if we are otherwise permitted to receive and process it under the data protection laws (including as set out below).
5. How is your personal data used?
5.1. We only process your Personal Data where we have a lawful basis for doing so and only in accordance with data protection laws.
5.2. When we ask you to supply us with Personal Data we will make it clear whether the Personal Data we are asking for must be given so that we can provide any products and/or services to you, or whether the supply of any Personal Data we ask for is optional.
5.3. We may use Personal Data about you (obtained by us as set out in this Privacy Notice), either on its own, aggregated, or combined with other Personal Data.
5.4. We process Personal Data as below.
We may process
- your personal data for marketing from time to time in accordance with the Marketing Statement. Note, that we may conduct some marketing as it in our (or a third-party’s) legitimate interest for us to do; or
- your special category data when we have obtained your explicit consent to do so.
We may process your special category data when we have obtained your explicit consent to do so.
You may withdraw your consent at any time. For:
- special category data, please contact us using the details in this Privacy Notice; and
- marketing, please see our Marketing Statement.
5.6. Performance of a Contract
We may process your Personal Data for including (but not limited to):
- effecting, processing, delivering and performing a contract you have entered into with or through us;
- helping us better understand your financial circumstances and behaviour so that we may make decisions about how we manage your Lending Works Account;
- effecting your transactional decisions including processing transactions you make in your Lending Works Account;
- making available to you certain functions and tools on our Website and Platform in relation to your Lending Works Account;
- communicating with you, including by telephone, e-mail and SMS, about your Lending Works Account;
- giving you important information about updated and new features and benefits associated with your existing products and services with us and benefits and to notify you about changes to our products and services;
- answering questions and responding to your requests;
- administering, servicing and managing your Lending Works Account; and
- carrying out any of our obligations arising from any contracts entered between us.
5.7. Legitimate Interests
We may process your Personal Data where it is necessary to pursue our, or third parties’, legitimate interests, including (but not limited to): - communicating with you in relation to any issues, complaints, or disputes;
- develop, improve and deliver marketing and advertising for products and/or services offered by us or another member of the Lending Works;
- improving the quality of experience when you interact with our products and/or services, including testing the performance and customer experience of our Website;
- performing analytics on sales/marketing data, determining the effectiveness of promotional campaigns;
- prevent and detect crime and/or assist with the apprehension or prosecution of offenders;
- providing you with newsletters, surveys, or information about our awards and events, offers, and promotions, related to products and/or services offered by us or another member of the Lending Works Group which may be of interest to you;
- making decisions about how we manage your Lending Works Account, including approving individual transactions;
- if you are a borrower or prospective borrower, making credit underwriting decisions, including assessing creditworthiness and affordability and the amount of credit we can make available to you;
- managing risks relating to our business, including credit risk (see below), fraud risk (see below) and operational risk;
- developing risk management policies, models and procedures used in the management of customers’ accounts and our business generally;
- Recording telephone calls: If you contact us by telephone, to help us improve our service, and for quality control and staff training, we may record and monitor telephone calls. We may also record and monitor telephone calls as necessary to comply with any legal and regulatory obligations, for the prevention of fraud and other financial crime and to protect the security of our communications systems and procedures.
Note: i) Where you do receive such marketing communications from us, you may change your preferences or unsubscribe from marketing communications at any time by clicking the unsubscribe link in an email from us; and ii) that you have the right to object to the processing of your Personal Data on the basis of legitimate interests as set out below, under the heading What Are Your Rights? How Do You Exercise Your Rights?
5.8. Where Required By Law
We may process your Personal Data if required by law.
We may process such data if necessary for reasons of substantial public interest, including for the prevention or detection of unlawful acts or in compliance with, or to assist third parties to comply with, any regulatory requirements relating to the investigation of unlawful acts, dishonesty or malpractice.
6. How is personal data used for marketing?
6.1 Our Marketing Statement sets out how we process your Personal Data for marketing, advertising, making available promotional offers and information, performing statistical analysis and conducting market research (including profiling).
6.2 Where applicable be given the choice of whether or not you wish to agree provide consent to marketing. This is not required for you to enter into any contract with Lending Works.
6.3. Please see our Marketing Statement.
7. Is personal data processed by automated means?7.1 The processing of your Personal Data will be performed by manual and automated means. To maintain the effectiveness and security of these systems, policies and procedures, we may also from time to time process your Personal Data for internal testing purposes.
8. Who do we share your personal data with?8.1 We may disclose any Personal Data we obtain under this Privacy Notice, for the purposes set out in this Privacy Notice, to:
- any party approved by you;
- any of our affiliates (including members of the Lending Works Group) and business partners if it is deemed necessary for the performance of a contract you have entered into with us, for our legitimate interests or the legitimate interests of a third party;
- institutional or corporate lenders on the Lending Works Platform;
- any retailers from whom you purchase or propose to purchase goods and/or services using
point of sale finance provided by us;
- service providers contracted to us in connection with our products, Website or provision of information, products and services, such as providers of IT services and customer relationship management services;
- our payment processors and suppliers and any third parties who process transactions submitted by us;
- any external providers of services and benefits associated with your Lending Works Account;
- collection agencies and lawyers to collect debts on your Lending Works Account;
- legal and other professional advisers, consultants, and professional experts;
- analytics and search engine providers that assist us in the improvement and optimisation of our Website;
- anyone to whom we may transfer our contractual rights; and
- any other person or party set out elsewhere in this Privacy Notice.
8.2 If you are a prospective borrower and cannot approve your loan application, we may offer you the opportunity to be referred to a partner loan broker. Where this is the case, we will only pass your Personal Data over if you agree to us doing this at that time.
8.4 If you have been referred to us by a credit broker, an intermediary, a retailer from whom you purchase or propose to purchase goods and/or services using point of sale finance provided by us, a lender, or another peer-to-peer lending platform, we may disclose Personal Data we obtain under this Privacy Notice to them if it is deemed necessary for our legitimate interests or their legitimate interests, for example, to calculate appropriate referral fees and commissions (if applicable).
8.5 We will ensure that there is a contract with such third-party service providers, which includes obligations in relation to the confidentiality, security, and lawful processing of any Personal Data shared with them, and which upholds your rights and freedoms concerning Personal Data.
8.6 We may also share Personal Data (including any special category data) with law enforcement or other authorities or agencies if required by law (including by way of a Court Order or where we otherwise deem it necessary to pursue our legitimate interests. This may include, without being limited to, responding to requests for information from such authorities or agencies, or sharing information with them in connection with our quality assurance processes, investigations, complaints, or appeals.
8.7 You should be aware that, where Personal Data is shared with a public authority, it will become subject to the Freedom of Information Act 2000 and may fall within the scope.
9. Credit reference and fraud prevention agencies9.1. We will exchange your Personal Data (provided to us as set out in this Privacy Notice) with credit reference agencies and fraud prevention agencies in this and the next section. We may also exchange your Personal Data which you have not provided us with credit reference agencies and fraud prevention agencies.
10. What about third-party account management?
11. Do we transfer your personal data outside of the uk?11.1. Any Personal Data we obtain about you may be held outside of the UK or European Economic Area ("EEA").
12. How do protect your personal data?12.1. We take all reasonable steps to ensure that both we and our third-party service providers protect your Personal Data. We use advanced technology, secure third-party suppliers and well-defined employee practices to help ensure that your Personal Data is processed promptly, accurately, completely and securely. We also ensure our staff are aware of their information security obligations, providing training, and limiting access to your Personal Data to staff who have a genuine business need to know.
13. How long do we keep your personal data?13.1. We will keep your Personal Data for the duration of any contract between us. Thereafter, we will keep Personal Data to:
14. What are your rights? how do you exercise your rights?14.1. General
15. How are cookies used?15.1 Our Website uses “cookies” and other technologies, which store small amounts of technical information on your computer or device, to allow certain Personal Data from your web browser to be collected.
16. how do you make a complaint?16.1 If you believe that your data protection rights may have been breached, you can:
- contact Lending Works via your Lending Works Account on the Website or using the details in this Privacy Notice. Details of our Complaints Procedure can be found at www.lendingworks.co.uk/complaints; and
- if we cannot resolve your concern, you may lodge a complaint with the applicable supervisory authority or seek a remedy through the courts. Please visit the UK Information Commissioner’s Office website for more information on how to report a concern. Note, you can also do this without first complaining to us.
17. Contacting you17.1 We may contact you by telephone, e-mail or in writing for general operational purposes and for administering your Lending Works Account, including to validate your identity.
18. What about changes?
18.1 We may change any provision of this Privacy Notice at any time without your permission.
18.2 When we make changes to this Privacy Notice, our updated Privacy Notice will be displayed on our Website or we will notify you by sending you a notification message within your Lending Works Account or by emailing you.