There are some administrative messages we will need to send to you as part of the services we provide ("Platform Messages"). We may send Platform Messages via email or text message. There may be other messages that we have the right to send you, but which you might wish to indicate that you do not wish to receive, or the manner in which you wish to receive them, via the feature in your Money Platform Account.
How we use and share your data
As a data controller, we may use your personal data, as defined in the Data Protection Act 1998 (“personal data”) and as the Lawful basis for processing personal data under the General Data Protection Regulation ("GDPR") as follows:
For internal operational purposes: statistical analysis; to develop and improve our products; to update our records; to identify which of our, or others', products might interest you; to assess lending risks; to identify, prevent, detect or tackle fraud, money laundering and other crime; to carry out regulatory checks; keep you informed about your lending or borrowing and for market research
We will only share your personal data with others for the purposes we explained when you applied to us, and/or:
if you ask us to, or give us your permission to do so;
to a credit reference agency to check your identity and to prevent fraud (they will also keep a record of your request and use it whenever anyone applies to be authenticated in your name);
if you are a Borrower, to tell credit reference agencies that you have an account and how you run that account;
to our agents and subcontractors, acting for us or for Lenders, to use for the purpose of operating the Platform and obtaining payment;
to investigate, prevent or detect fraud or carry out checks against money laundering;
to share Data via an organisation which provides a centralised application matching service which it collects from and about mortgage and/or credit applications, for the purpose of preventing and detecting fraud;
to a reputable, licensed credit broker or lender in the event that you apply to borrow money on the Platform, your application is declined or the loan monies are otherwise unavailable and we reasonably believe that the credit broker or lender may be able to help you obtain a loan. In these cases, the third party may use your personal data provided via the Platform application to perform a soft search with a credit reference agency to check your eligibility for their products. A soft search will not impact your credit rating;
to trace debtors and recover debt;
to meet our obligations to any relevant regulatory authority or taxing authority;
if we have to by law, the law allows it, or it is in the public interest; and
if all of the assets which we use to operate the Platform (or substantially all of them) are acquired by a third party, we may transfer personal data we then hold to that party so that the acquirer can continue to operate the Platform.
Equifax, Experian and TransUnion, the ICO and major financial services trade associations, we have developed a common statement, Credit Reference Agency Information Notice (CRAIN), defining the standards that all three Credit Reference Agencies will apply across all products and services in relation to processing consumer data. This can be found here.
If your loan is subsequently not funded by The Money Platform, in order to facilitate your search for a loan, we may pass your details to Digitonomy trading as Little Loans, a credit broker authorised by the FCA (authorisation number 690249), to help you find a loan. If you choose to use the services or brands of Digitonomy to further your loan search, Digitonomy will conduct a soft credit search which will not show on your credit file. Your details may be passed to other lenders - these lenders may carry out additional soft credit searches in order to assess whether they are able to offer you a loan and you may be contacted by SMS, email, telephone or automated message by any lender that has approved your application for the purpose of progressing your application with them. Note that in passing your details to credit brokers, The Money Platform is itself acting as a credit broker (i.e. an introducer) and will receive a commission directly from the credit broker following a successful introduction. You can view the privacy policies of Digitonomy (trading as Little Loans) here.
We will check your details with a fraud prevention agency or agencies, and if you give us false or inaccurate Data and we suspect fraud, we will record this. If false or inaccurate Data is provided and fraud is identified, details will be passed to fraud prevention agencies, in which case we and other organisations (including law enforcement agencies) may use, search and access these records from the UK and other countries (e.g. offshore operations of UK businesses) to:
help make decisions about credit and credit related services, for you;
help make decisions on motor, household, credit, life and other insurance proposals and insurance claims, for you and members of your household;
trace debtors, recover debt, prevent fraud, and to manage your accounts or insurance policies;
check your identity to prevent money laundering, unless you furnish us with other satisfactory proof of identity; and
Any credit reference agency we search will keep a record of any search, and other Lenders may use it to assess applications they receive from you in the future.
Generally, we will give you at least 28 days’ notice if we decide to file a default on your credit reference file. However, we may not always give you notice beforehand, for example, if we plan to take court action.
Transfers outside the UK
We may transfer your personal data abroad to countries whose Data protection laws are less strict than in the UK. If so, we will ensure the Data is held securely to standards as least as good as those in the UK and only used for the purposes set out in this clause.
Your access rights
Under the Data Protection Act 1998, you have a right to access certain personal records we, credit reference agencies and fraud prevention agencies hold about you. This is called a "subject access request", which you can make by writing to us at firstname.lastname@example.org. A fee may be payable, but we will not charge you until we have told you how much the fee is and what it is for, and you have told us you still want to proceed.
right not to be subject to automated decision-making including profiling
In terms of any data held or used by The Money Platform to support our decision making process.
Contacting Other Customers
We will not disclose your personal data to any other Client unless it is necessary to enforce any Loan Contract. If you receive such Data, you are not permitted to use it directly, other than in communication with us about your Loan Contract(s).
You agree that, in the course of generating and managing your Loan Contracts, and operating the Platform, we will need to send to Lenders and their assignees or the Borrower, as the case may be, certain transactional Data (for example, unique identifier, loan amount and Repayment details) but not your full name, post code address or payment details. We will not be liable for any use or misuse of the transactional data by others, but you must inform us of any misuse of the Platform of which you are aware.
Monitoring and Recording
We may monitor, record, store and use any telephone, email or other communication with you in order to check any instructions given to us, for training purposes, for crime prevention and to improve the quality of our service.