This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed and used by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. Your data will only be used in a manner that is consistent with our obligations and your rights under law.
We take your privacy seriously and will only use your personal information to provide you the products and services you have requested from us and to administer your account.
Valour Finance Limited trading as Savvy.co.uk whose registered office is at First Floor, Highbank House, Exchange Street, Stockport, England, SK3 0ET. Our Data Protection Registration Number is Z1012907.
We receive, hold and process information relating to individuals (‘personal data’) in accordance with the Data Protection Act 2018 and General Data Protection Regulation. In doing so, the company is committed to maintaining the privacy and protection of all personal data collected in pursuance of its broker and loan services. As a company, we are further committed to ensuring that our website is secure in the collection and use of your personal information.
When you apply for or enquire about a loan, or our other services, we will collect personal information about you which may include the following:
To apply with us you must be 18 years of age or older.
Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you or to take steps, at your request, to enter into a contractual relationship.
We will rely on your consent to share your personal information with third parties to we select to send you marketing information about products and services that we think that you may be interested in.
We will rely on your consent to process your personal information to send you future marketing information about our products and services that we think you may be interested in.
We collect information with a view to offering you a loan whilst satisfying regulatory requirements and making our lending decision. We will confirm your identity to prevent fraud and money laundering.
Your information will be processed by our decision engine via savvy.co.uk and our employees and agents who will have access to the information you have provided. We will use your information to make a lending decision and if we lend to you to manage your loan account.
We will use your information as follows:
We may 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 Valour Group (UK) PLC or it may be from other organisations offering related products and services or from other organisations whose products or services we think may be of interest to you. We will only transfer your personal data to third parties for marketing purposes with consent. We will notify you about the identity of the third parties and ensure that they handle your data responsibly and compliantly wherever reasonably possible.
We may disclose your personal information to third parties as part of our regulatory requirements, as required by law or as you have provided consent to do so.
We may share your personal information with selected third parties including:
For the fulfilment of some of our services to you we transfer some data outside of the European Economic Area (“EEA”). Where we transfer data outside of the EEA we have ensured that adequate protection is in place and appropriate safeguards are applied.
Please see below for more details:
We use safeguards such as Commission approved model clauses, and other safeguards when transferring personal data outside the EEA. For more information or to obtain a copy of these safeguards, please contact us as set out at the end of this Policy.
What is Open Banking?
Open Banking is a secure way of providing us with access to your bank account or building society transactional data. By permitting us with access to your bank or building society account we are able to make a lending decision by verifying your income, outgoings and other transactional banking data.
Open Banking was set up by the UK Government to encourage more competition and innovation in the financial services sector.
Registered providers and participating banks and building societies are listed under the Open Banking Directory. Further information about Open Banking is available from www.openbanking.org.uk.
How will my personal data be shared and used for the purposes of Open Banking?
By proceeding with your loan application via our website you expressly consent to us accessing, processing and storing transactions from your personal bank or building society account, and for us to share this data with our Open Banking software provider.
Is Open Banking secure?
Any data we access will be encrypted and its usage tracked as part of the Open Banking data security standards.
You will not be required to share your banking password or log in details with us. Please ensure you never give these to anyone pretending to be us by email or over the phone.
Will you use my Transaction Information data for any other purpose?
The Transaction Information we receive about you will only be used for the purposes of making our lending decision, and for the management of your loan. We do not sell or share this transaction data with any third party.
Do I have to provide you with my consent to proceed?
You do not have to provide us with consent, however, we may decline your application if you do not do so because Open Banking enables us to view your income, outgoings and other transactional data in order for us to make our lending decision.
Under Open Banking as your personal data is shared by your bank or building society and accessed by us you may also be able to exercise your individual data protection and privacy rights against your bank pursuant to their own terms and conditions and privacy policies.
It is your responsibility to review and check your declared information to ensure that it is true, accurate and specific to your financial circumstances.
We rely on the information submitted by you as part of your loan application, to assess that the loan amount requested and the associated repayments are affordable for you, based on our lending criteria.
It is important that all information which you provide us with during the application process is accurate and truthful.
We take no responsibility for lending to you based on you having provided us with false, incorrect or fraudulent information.
You also agree that by making the application with us that you are providing us with truthful information and you are not currently experiencing financial difficulty and are not considering entering, or currently on a debt management plan, IVA, bankruptcy, or any other debt help solution.
When you apply for a loan you consent to us making a credit search with a ‘CRA’. We may also make additional credit searches during our relationship to help us manage your account effectively and you provide consent to these searches.
When CRAs receive a search request from us they will place a search “footprint” on your credit file that may be seen by other lenders and finance companies. CRA’s use both public (including the electoral register) and shared credit information. Large numbers of applications or credit searches within a short period of time may reduce your ability to obtain credit.
If you tell us that you have a spouse or financial associate, we will link your records together so you must be sure that you have their agreement to disclose information about them. CRAs also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.
Information on applications will be sent to CRAs and will be recorded by them. Where you borrow from us, we will give details of your accounts and how you manage it / them to CRAs. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs and FPAs to perform similar checks and to trace your whereabouts and recover debts that you owe. This may affect your ability to obtain credit in the future.
Credit records remain on your credit file for a period of 6 years after which date they are closed, whether settled by you or following a default.
You must be truthful and not withhold or provide false information when you are dealing with us. If you provide us with false or inaccurate information or we identify fraud, details may be passed to FPAs and other organisations involved in crime and fraud prevention including law enforcement agencies who may then access this information.
We and other organisations may also access and use this information to prevent fraud and money laundering, CRAs and FPAs may use your information for statistical analysis. Information held by CRAs and FPAs will be disclosed to us and to other organisations in order to, for example, when:
We and other organisations may access and use, from other countries the information recorded by fraud prevention 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 GDPR.
The three main Credit Reference Agencies, TransUnion, Equifax and Experian will use and share your data in line with the Credit Reference Agency Information Notice (CRAIN) for further information on how CRA’s use your data please visit their websites as stated below.
Should you wish to obtain a copy of the personal data other agencies hold about you please write to:
The Fraud Prevention Agency that we use is Action Fraud - www.actionfraud.police.uk
If you wish to see the information contained on a credit reference agency file you can do so by writing to the relevant agency. The agency must respond within one month. If your credit reference file contains information about other people with whom you have no financial connection or if it contains information which is incorrect you can ask for the entry to be corrected, removed, or have a note put on the file explaining why you think the information is wrong. The agency will not remove correct information.
The Information Commissioner’s Office provides a useful leaflet which explains how to request changes to your credit reference file. The easy to read leaflet includes examples of letters and details of various actions you may take to amend a file.
Information is available at https://ico.org.uk/media/for-the-public/documents/1282/credit-explained-dp-guidance.pdf.
Credit reference agencies keep a wide range of information. This includes information from the electoral roll (sometimes known as the voters’ roll) and records of most county court judgements and bankruptcies. They also retain information relating to previous and existing credit and a record of searches made against the file. The lenders share information through the agencies providing a history of how punctually payments are being made or have been made. Loan information is usually held on file for 6 years once settled. Details of the Electoral roll may be held for much longer. Information about credit searches is kept for 12 months.
Reports from CIFAS relating to fraud and fraud avoidance are also available to most lenders – these contain information indicating that fraud, or attempted fraud, has been notified by a lender. The information might not directly relate to you, it might relate to someone who has tried to impersonate you. Data available to members of CIFAS may also be used to help make decisions on motor, household, credit, life and other insurance proposals for you and members of your household. CIFAS information is intended to warn lenders and act as a protection for innocent customers.
The Council of Mortgage Lenders, Repossession Register is available through the main credit reference agencies. If you have had a property repossessed or have given it up voluntarily this will show on the register.
A file may also show a “gone away” marker indicating that a member of the “Gone Away Information Network” has reported that they cannot trace a customer who is in arrears with payments. Alternatively, the marker may indicate a new address which the “gone away” has been traced to.
Files in this register contain detailed information on applications made and loans given. It is aimed at tracing fraudsters who use different combinations of information to obtain credit dishonestly. It checks and counter checks information given on application forms.
If we use any of the above agencies they will be able to confirm their contact addresses.
Your information is stored electronically within our servers and case management systems. Some of your information is segregated to reduce risk, access is controlled and our systems are backed up regularly to ensure confidentiality, integrity and availability. Any payment transactions will be encrypted using SSL technology.
Where we have given a password PIN code which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
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 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. In these circumstances we will only retain minimum information to enable us to honour your suppression request.
We will generally keep records of any transactions you enter into 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, namely future marketing of products and services which may interest you. We give you the option to opt-out of receiving any future marketing communication within each communication.
We will keep all call recordings for a maximum period of 6 years from the date of recording.
We will keep all emails for a maximum period of 6 years from the date of receipt/send.
We will keep other information about you if it is necessary for us to do so to comply with the law, regulations, or where appropriate for legitimate business needs, namely marketing. 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, namely until you notify us of a change in your marketing preference.
Where an application has had a soft search completed but does not enter into a contract with us that data will be retained for a period of 6 months for the purpose of any dispute or complaint that may arise.
If you wish to find out how long your information is held for with the third parties we share your information with, their contact details are provided under how to find out more within this notice.
All communications between us, including contractual documentation, will be sent electronically unless otherwise required by law or unless you otherwise ask us to communicate with you in paper form. We will send all communications and documentation to the particular electronic address provided by you and registered to your account.
The right to be informed
We will provide you with the following information:
The right of access
You have the right to submit a Subject Access Request at any time. This means that you are entitled to all personal data we hold about you, including files notes, emails, call recordings etc.
Once a request has been received we will respond within one calendar month; however this may be extended by up to two months if the request is complex and/or numerous request are made.
No fee will be charged for handling such a request however we reserve the right to charge reasonable fees for additional copies of information that has already been provided or where the request are manifestly unfounded or excessive, in particular where requests are repetitive.
Should you wish to obtain a copy of the personal data we hold about you please write to us at the address shown below. As soon as we are satisfied as to your identity we will send you, and within the legislated time, depending on the date of your request, a copy of the data we hold concerning you.
The right to rectification
You have the right to request to rectify any inaccurate or incomplete personal data about you. Such a request will be completed within one month of receipt; we reserve the right to extend this period by up to two months in the case of complex requests.
The right to erasure (also known as the right to be forgotten)
You have the right to request that we erase the personal data we hold about you in the following circumstances:
Unless we have reasonable grounds to refuse to erase personal data, all requests for erasure will be complied within one month of receipt of their request. We reserve the right to extend this period by up to two months in the case of complex requests.
The right to restrict processing
You may request that we cease processing your personal data. If you make such a request, we will retain only the amount of personal data concerning you (if any) that is necessary to ensure that the personal data in question is not processed further. For example, your marketing preferences.
We may only continue to process data where:
The right to data portability
Where you have given your consent for the Company to process your personal data in, or the processing is otherwise required for the performance of a contract, you have the right to receive a copy of your personal data and to use it for other purposes.
To facilitate the right of data portability, we will make available all applicable personal data in the following way:
All requests for copies of personal data will be responded to with within one month. We reserve the right to extend this to two months in the case of a complex request and will ensure that you have been informed of the extension.
The right to object
You have the right to object to us processing your personal data based on legitimate interests, direct marketing (including profiling).
Where you object to us processing your personal data based on your legitimate interests, we will cease such processing immediately, unless it can be demonstrated that our legitimate grounds for such processing override your interests, rights, and freedoms, or that the processing is necessary for the conduct of legal claims.
Where you object to us processing your personal data for direct marketing purposes, we will cease such processing immediately.
If you do not want us to use your personal data to contact you by electronic means (email or SMS) with information about other products offered by any company within the Valour Group (UK) Plc, or other third parties you can revoke your consent by opting out please contact us at email@example.com or call 0330 002 0118.
Rights with respect to automated decision-making and profiling
You have the right to obtain human intervention, to express your point of view and to contest a decision which we make on an automated basis.
If you are not satisfied with how we handle your personal data, in the first instance, please contact us at firstname.lastname@example.org.
Should, you remain dis-satisfied, then you may contact the Information Commissioners Office:
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Tel No: 0303 123 1113
Important information about our loans. Please take time to read about us and how we operate as we take our responsibilities and duties as a provider of consumer finance seriously.