Privacy Policy

Introduction

 

Savoys Lending Limited (the lender, we, us and our) is committed to protecting your privacy. This notice sets out the personal information that we may collect or obtain about you and how we treat that information.

 

For the applicable data protection legislation, we are a data controller in respect of the information that we collect or obtain about you. This is because the lender is the person who (either acting alone or jointly with others) determines why and how your personal information is processed.

Please contact our data protection officer on info@savoyslending.co.uk, if you have any queries about the privacy notice or if you wish to exercise any of your rights in respect if data protection as detailed below.

 

The information we process about you

 

Your personal information will be collected or obtained by us whether we deal with you as an individual or on behalf of an individual, business or any other organisation you represent. In broad terms personal information (Or personal data) is any information that can identify you as an individual. We process several types of personal information for example, your name, your address and date of birth. We may process personal data relating to criminal convictions and offences providing we have your consent to do so or for fraud prevention purposes.

 

We may also process special categories of personal information for example, information relating to your health providing you have given us your explicit consent to do so. Please be aware that if you provide us with documents that contain, or otherwise notify us data that constitutes a special category then you will be regarded as to having provided us with explicit consent to us processing that data as described in this privacy policy. If you do not consent to us processing special categories of personal information about you, then that may limit what we are able to do for you, as we always look to process information in a way that treats you fairly and in line with your needs.

 

If you have made an application on behalf of another person, a joint application with another person, or an application on behalf of a business or other organisation and have provided us with personal information in relation to its directors shareholders, owners, trustees or beneficiaries, or if you have provided us with personal information in relation to any guarantor, provider of security, or any occupier of any security property then this
privacy policy notice will also apply the information that we collect or obtain about these individuals. You must provide a copy of this notice to those individuals as soon as possible and obtain their confirmation that they have read and understood it.


Why we process your personal information

 

1 There are several reasons and legal bases for which we process your personal information, depending on the reason for which we have collected or obtained your personal information. The main type of processing that we carry out and the legal basis for doing so are as follows

 

2 We process your personal information to enable us to consider your application or enquiry regarding our credit products. This is necessary to take steps at your request before we enter into an agreement with you and is also necessary for our legitimate interests for example in deciding as to whether to offer you the product that you have applied for. This type of processing is required for you to enter into an agreement with us. If you do not provide the information, then we cannot proceed with your application. In respect of fraud searches and identity verification this processing is necessary for our legitimate interests for example fraud prevention and compliance with our legal obligations.


3 If your application is accepted we will process your personal information to administer your account in several ways, for example, collecting loan repayments, providing you with statements of your account, notices, and managing any arrears on your account, enforcing any security that we have in place and dealing with any queries and complaints that you may have. This type of processing is necessary for the performance of our contract with you and to fulfil our legal obligations.

 

4 We will also process your personal information to manage our business operations, for example monitoring communications and activities in relation to your account, and for accounting and audit purposes. We have legitimate interests in doing so as it is necessary for our business and compliance purposes and we may also have legal obligations to fill.


5 If your application is declined, we will store your personal information in accordance with our retention procedures and to comply with our legal obligations.


6 If we are dealing with a request you have made to exercise your legal and regulatory rights, this will be done to fulfil our legal obligation to respond to you.


7 We process your personal information for marketing purposes. This is necessary to fulfil our legitimate interests of providing you with information about products and services that you may have been interested in.


8 The personal information that we process when you are browsing our website for example your IP address is done so on the basis that we have legitimate interests in doing so for example to help enable us to tailor the advertisements that we display to you on our website, or that you have given your consent to this by accessing and browsing the website


9 If you are a guarantor or provider of security, we will process your personal information to check that we are able to accept that guarantee or security and/or to enforce that guarantee or security. This is necessary to fulfil our legitimate interests for example to ensure that we can recover any sums that we have advanced to our customer should that customer not keep up with their repayments to us.


10 If you are an occupier of any security property we will process your data to ensure that there is no conflict between your rights and our rights in respect of the relevant security property. This is necessary to fulfil our legitimate interests for example to ensure that we can enforce our rights in respect of the security property should our customer not keep up with their repayments to us.

 

The consent given will be as simple to withdraw as it was to give. Withdrawing you consent does not affect the lawfulness of any processing which occurred prior to the withdrawal of the consent. If you do this and if there are no alternative legal basis upon which we may process your personal information for a purpose, then this may affect what we can do for you.

 

Who your personal information will be shared with


Your information may be shared with the following third parties;

 

1 Credit reference agencies and fraud prevention agencies to carry out credit and fraud searches and to verify your identity. This type of processing is
necessary for our legitimate interests for example fraud prevention and compliance with our legal obligations

 

2 Anyone acting on your behalf whom has authority to do so, such as a debt charity, power of attorney or your professional advisors.

 

3 Legal and regulatory bodies such as the financial conduct authority, the prudential regulation authority, HMRC, the information commissioner’s office, the financial ombudsman, fraud prevention agencies, our professional advisors and/or the courts when it is necessary for our legitimate interests for example to obtain legal advice or for fraud prevention purposes and/or when we have a legal obligation to do so.

 

4 Organisations that provide us with business support services, for example back up and server hosting, IT software and maintenance platforms, document storage and management services, receivers, repossession agents, and property valuers. This processing is undertaken as it is necessary for the performance of our agreement with you and is necessary for our legitimate interests for example for our commercial operations.

 

5 Third parties who have introduced you to us for example an intermediary or broker, for them to manage their records about you, to ensure that the type of business they refer to us is appropriate and to help us to resolve any complaint made by you and/or any dispute between you and us. This type of processing is necessary for our legitimate business interests for example to help us ensure that the intermediary or broker is fulfilling their terms of their contract with us and for us to fulfil our legal obligations for example our complaint handling obligations.

 

6 Any person or entity that is to provide or has provided any security of guarantee and their professional advisors in respect of your agreement with us and their professional advisors. This type of processing is necessary for the fulfilment of our contract with you for example to enable us to recover any sums we have advanced under our agreement with you.


7 Any entity and their professional advisors that provides funding to us, any entity that provides us with debt or equity finance and any potential purchasers of the business. This type of processing is necessary for our legitimate interests for example to enable us to fund our business.


8 Market research organisations who we engage with to help us develop and improve our products and service. This type of processing is necessary for our legitimate interests for example our commercial operations.

 

As mentioned if you voluntarily provide us with special categories of your personal information this will be regarded as having provided your explicit consent to us processing this information. This would include us sharing that information with the above mentioned third parties where required. For example, if you provide information relating to a complaint you have made or made us aware of financial difficulties you may be experiencing then you will be consenting to us sharing that information with third parties for example your intermediary or broker, administration companies, or the financial ombudsman service, and our professional advisors. We will however always seek to confirm with you that you do consent to us processing special categories of your personal information that you have voluntarily provided to us, and to us sharing that information with third parties as necessary.

 

How we collect your personal information


Personal information can be collected directly from you in several ways;

 

1 When you apply to Savoys Lending Limited for a credit product via our website, through a postal application or direct through one of our employees


2 On line, or by any other method of communication for example, enquire now, apply now, contact us forms, or when you provide it through the course of our relationship for example if you inform us of a change in your circumstances or if you make a subsequent application to us, for example an application for another property

 

3 Technical information including the internet Protocol address used to connect to the internet may be collected from you when you visit our website.


Personal information may also be collected indirectly from third parties in the following ways;

 

1 Through one of our intermediary partners, on their website, or if you visit their office or they visit your home


2 An introduction to us by another third party such as an accountancy firm, law firm or management consultancy


3 When another person provides your information to us when they apply to obtain a product from us, on behalf of yourself, that is to be held jointly with you, on behalf of a business, or other organisation which you are a director, shareholder, owner, trustee or beneficiary. You have been nominated as a guarantor under our agreement with them, or to provide any other security or informed us that you are an occupier of any security property


4 Fraud prevention agencies, credit reference agencies, companies house when we carry out searches for processing your application and/or during your relationship with us.

 

If you have applied to us through a third party then they should have provided you with a copy of their own privacy policy notice to tell you how they may process your personal information, this can be on line or in person. They should also have told you that credit reference and fraud prevention agency checks will be performed before we will consider your application more fully and that your personal information is being shared with us for the purpose and uses set our in this privacy notice. If the third party did not tell you this then you should let us know immediately by contacting our data protection officer using the contact information set out in the introduction section of this privacy notice.

 

Credit reference checks


To enable us to process your application we will perform credit and identity checks on you with a credit reference agency. To do this we will supply your personal information to the credit reference agency and they will provide information about you to us. This will include information from your credit application and about your financial situation and financial history. Credit reference agencies will supply both public and shared credit, financial situation and financial history information and fraud prevention information.

 

We then use this information to;


1 Assess your creditworthiness and whether you can afford to take the product
2 Verify the accuracy of the data you have provided to us
3 Prevent criminal activity, fraud and money laundering
4 Manage your accounts
5 Trace and recover debts
6 Ensure any offers made to you are appropriate to your circumstances

 

We will continue to exchange information that we have about you with the credit reference agencies whilst you have a relationship with us. We will also inform the credit reference agencies about your settled accounts. If you borrow and do not repay in full and on time credit reference agencies will record the outstanding debt. This information may be supplied to other organisations by the credit reference agencies.


When the credit reference agencies receive a search from us they will place that search footprint on your credit file that can then be seen by other lenders. If you are making a joint application or tell us that you have a spouse or financial associate we will link your records together, so you should make sure you discuss this with them and share with them this information before making the application. Credit reference agencies will also link your records together and these links will remain on your and their files until you or your partner successfully files for a disassociation with the credit reference agencies to break that link.


The identities of the credit reference agencies, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection right with the credit reference agencies are explained in more detail in the CRA information notice referred to as the CRAIN. Crain is assessible from each of the three credit reference agencies by clicking on any of the links below, each link will take you to the same document.

 

• Equifax
• Experian
• Call Credit

 

Your rights under applicable data protection law


Your personal information is protected under data protection law and you have several rights which you can seek to exercise. Please contact our data protection officer using the contact information set out in the introduction section of this privacy notice if you wish to do so or if you have any queries in relation to your rights.


If you seek to exercise your rights we will explain to you whether the rights apply to you, these rights do not apply in all circumstances. Please be aware that your request is manifestly unfounded or excessive we may refuse to deal with your request or may charge a reasonable fee for dealing with it.

 

Right to access


You have the right to access the personal information held about you and to obtain certain prescribed information about how we process it. This is more commonly known as submitting a data subject request. We may request proof of your identity before sharing such information.


Right to rectify your personal information.

 

If the information we hold about you is inaccurate or incomplete you have the right to have this information rectified.

 

Right to be forgotten


You may ask us to delete the information we hold about you in certain circumstances this is often referred to as the right to be forgotten. This right is not absolute and only applies in certain circumstances. It may not therefore be possible for us to delete the information we hold about you, for example if we have an ongoing relationship or are required to retain information to comply with our legal obligations or to exercise or defend legal claims.

 

Right to restriction of processing


In some cases, you may have the right to have the processing of your personal information restricted, for example where you contest the accuracy of personal information, I may be restricted until the accuracy is verified, or where the processing is unlawful, but you object to it being deleted and request that it is restricted instead.

 

Right to object to processing


You may object to processing of your personal information when it is based upon our legitimate interests. You may also object to the processing of your personal information for the purposes of direct marketing and for the purposes of statistical analysis.

 

Right to data portability


You have the right to receive, move, copy or transfer your personal information to a controller which is also
known as data portability. You have the right to this when we are processing your personal information based on consent or on a contract and the processing is carried out by automated means. You should note that this right is different from the right of access and the types of information you can obtain under the two separate rights may be different.

 

How long your personal information will be stored for


The personal data that we hold on you is only kept for as long as it is necessary to fulfil the purposes for which it is processed.

 

Your personal information will be retained for a minimum of 6 years from the end of our business relationship with you. The business relationship will be deemed to be at an end on the date in which your account is closed, which will either be when all outstanding sums under the agreement have been repaid or when we stop perusing arrears on the account, or when your application has been declined, or when you decide not to proceed with an enquiry or application with us.

 

Please be aware that if your personal information is shared with third parties they may hold different retention policies. Fraud prevention agencies can hold your data for different periods of time, if you are considered to pose a fraud or money laundering risk, note that your data can be held with them for up to 6 years.


Further information in respect of how fraud prevention agencies may hold your information can be found at savoyslending.co.uk

 

Keeping your information accurate


We endeavour to keep your personal information up to date and accurate. If any of the personal information you have given us or third parties changes for example your contact detail’s, please inform us in accordance with the terms and conditions of your agreement with us.


You will be required to provide us with any changes to your personal information under the agreement you enter with us if your application for a credit product is accepted. If you fail to do so this will put you in breach of your agreement.

 

How we monitor your communications


Subject to applicable laws we will monitor and record calls, emails, text messages, social media messages and other communications. We will do this for the purposes of complying with applicable laws and regulations and our own internal policies and procedures to prevent or detect crime, to protect the security of our communications systems and procedures and for quality control and staff training purposes.

 

What to do if you have concerns and wish to make a complaint


If you are concerned about the use of your information, please notify our data protection officer as soon as possible using the contact information set out in the introduction section of this privacy notice. If we cannot resolve a complaint to your satisfaction you can contact the ICO
at www.ico.org.uk or by telephoning 03031231113 if the complaint relates to the way your personal information has been handled.