Privacy Policy for Short Term Loans UK

Updated: 21 / 11 / 2023

1. Introduction

Welcome to shorttermloansuk.co.uk privacy notice.

shorttermloansuk.co.uk is a trading style of Cobain Digital Ltd company number 08954504. which is authorised and regulated by the Financial Conduct Authority Permission Number 713027. Cobain Digital Ltd are a credit broker not a lender. 1st Class Loans does not provide any loan or consumer Credit products directly.

Cobain Digital respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

 

2. Important information and who we are

Purpose of this privacy notice

This privacy notice gives you information on how Cobain Digital collects and processes your personal data through your use of this website, including when submitting your application, your application will then be sent to our panel of lenders and brokers to attempt to fulfil your financial request.

This website is not intended for children, and we do not knowingly collect data relating to children.

Controller

Cobain Digital LTD is the controller and responsible for your personal data (collectively referred to as “T.UK”, “we”, “us” or “our” in this privacy notice).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 8th December 2022 and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notices. When you leave our website, we encourage you to read the privacy notice of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, marital status, number of dependents, title, date of birth and gender.
• Contact Data includes address, email address and telephone numbers.
• Financial Data includes bank account and payment card details, employer name and industry, time at employer, net monthly income (which may include details of any benefits you receive), pay frequency, pay dates, and expenses details.
• Transaction Data includes details about your requests for offers of credit from our trusted third-party partners.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your requests for offers of credit from our trusted third-party partners, preferences and feedback.
• Usage Data includes information about how you use our website, products and services.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data, but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). However, we do recognise that details of any benefits you may receive could lead to inferences about your health being made. We do not collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we will not be able to perform the contract we have or are trying to enter into with you (for example, to process a request for an offer of credit from our trusted third-party partners).

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • request an offer of credit from our trusted third party partners;
  • request marketing to be sent to you;
  • give us feedback.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy below for further details.
• Third party sources. We may receive personal data about you from various third parties as set out below:

– Technical Data from the following parties:
a. analytics providers such as Google based outside the UK;
b. advertising networks based inside and outside the UK; and
c. information processing providers based outside the UK.
d. Social Media Platforms such as Facebook, Instagram and TikTok, based outside the UK;
– Identity and Contact Data from data brokers or aggregators based inside and outside the UK.
– Trusted affiliate websites, networks and third party partners.

4. How we use your personal data

Under data protection laws we are permitted to share some information where the reason for doing so is legitimate and isn’t outweighed by the effects it will have on the relevant individuals. On that basis we may pass your information to Data OD Ltd who may share this information with other third parties.

The data that is shared may be used for analysing, modelling and contact for purposes including affordability assessments, anti-money laundering, asset repatriation, contact information validation, credit risk and affordability assessments, debt collection services, determining debt portfolio value, fraud prevention services, identity verification services, pre-populating online forms, vulnerability assessments and other related services.

If you do not wish for your data to be used this way by Data OD Ltd please opt-out using this link https://dataondemand.co.uk/opt-out/ You can use this link to opt-out at any time after you have shared your data. You can also email MyInfo@dataondemand.co.uk with any requests about your information. For additional information about how your data is processed by Data OD Ltd, please use this link https://dataondemand.co.uk/personal-data-privacy-notice/

We will only use your personal data when the law allows us to.

Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or SMS. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To process your requests for offers of credit from our trusted third-party partners	(a) Identity (b) Contact (c) Financial (d) Transaction	Performance of a contract with you. This will include automated decision-making on the part of our trusted third-party partners
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive a respectful amount of marketing communications from us, in relation to the services that we offer. Our lawful basis for this is legitimate interest. If you wish to opt-out, please contact us at info@t.uk

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

– Internal Third Parties as set out in the Glossary.

– External Third Parties as set out in the Glossary.

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

6. Data profiling and decision making

We do not use your personal data to make automated decisions about you or to profile you. However, our platform uses software to automate the order in which your personal data is passed to our third-party lenders and partners.

We provide data that may help third party lenders and partners make decisions about lending and other matters (such as preventing fraud or protecting consumers), but their own data, knowledge, processes and practices will also generally play a significant role in their decisions – and those decisions will always be for them to make.

For example, we do not decide whether you should be granted credit or a loan – this is for the lender to decide. However, they will ultimately decide how to act upon that information, considering their legal and regulatory obligations.

7. International transfers

Some of our external third parties are based outside the United Kingdom (UK) so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by using specific contractual clauses which give personal data the same protection it has in the UK.

Please contact us  if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

8. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other service providers who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are listed and described below:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b)where our use of the data is unlawful but you do not want us to erase it;(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• If you wish to exercise any of the rights set out above, please contact us.

No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. Glossary

LAWFUL BASIS

• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies acting as joint controllers or processors and who are based in the United Kingdom and the United States and provide IT and system administration services and undertake leadership reporting.
– Other companies acting as joint controllers or processors and who are based outside the UK and provide software development and engineering services.

External Third Parties

– Service providers acting as processors based in the EEA, the United Kingdom and the United States who provide IT and system administration services.
– Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom and the United States who provide consultancy, banking, legal, insurance and accounting services.
– HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who may require reporting of processing activities in certain circumstances.
– Google, Linkedin, Facebook to enhance targeting / exclusions from advertising.

– Our network of trusted third party affiliate websites, third party affiliate networks, third party digital marketers, and third party lender partners.

– Third parties for the purpose of analysing, modelling and contact for purposes including affordability assessments, anti-money laundering, asset repatriation, contact information validation, credit risk and affordability assessments, debt collection services, determining debt portfolio value, fraud prevention services, identity verification services, pre-populating online forms, vulnerability assessments and other related services