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Welcome to Careys Credit Services Limited (“Careys”) Privacy notice.
Careys 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 and submit a loan application (regardless of where you visit it from) or when you submit an application form with one of our agents, and tells you about your privacy rights.
Please also use the “Glossary” to understand the meaning of some of the terms used in this Privacy notice.
This Privacy notice aims to give you information on how Careys collects and processes your personal data which you may provide through our website or when you visit our office.
Our website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this Privacy notice together with any other Privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy notice supplements the other notices and is not intended to override them.
Careys Credit Services Limited (trading as “Careys Personal Credit”) is the data controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this Privacy notice) and is responsible for our website.
We have appointed a Data Protection Manager, Phil Carey, who is responsible for overseeing questions in relation to this Privacy notice. If you have any questions about this Privacy notice, please contact Phil using the details set out below.
Careys Personal Credit
1-3 Kensington Road
Middlesbrough TS5 6AL
Name of the Data Protection Manager: Phil Carey
Phone: 01642 850022
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. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
This version was last updated in March 2018.
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.
When you use our website, it 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 statements. When you leave our website, we encourage you to read the Privacy notice of every website you visit.
Personal data 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:
We may keep a record of any correspondence which is sent to you or received by us from you which includes some of the above Data.
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). Nor do we collect any information about criminal convictions and offences.
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 may not be able to perform the contract we have or are trying to enter into with you (i.e. to provide you with financial services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through our website, when you apply for a loan and/or use other services online, or when you visit our office.
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:
We would like to make you aware that we may record telephone calls and record visits to our premises using CCTV for the purposes of training, policy administration, security and complaints handling (when it is in our legitimate interest to do so).
When you interact with our website, we may automatically collect data about your browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.
We may receive personal data about you from various third parties and public sources as set out below:
When you use our website, Technical Data from the following parties:
When you use our website, or when you submit an application form via one of our agents in person:
Contact, Financial and Transaction Data from providers of technical and payment services such as third party debit card processors.
Financial Data from the following parties:
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:
You are an individual at economic risk when you are less able to protect your economic wellbeing by reason of physical or mental injury, illness or disability. Such personal circumstances may change during the course of your dealings with us, and our agents will regularly evaluate and assess this. If you require further information about the exemption and/or when it may be relied upon, please do not hesitate to contact us.
Generally we do not rely on consent as a legal basis for processing your personal data, other than in relation to sending you direct marketing communications via email or post. You have the right to withdraw consent to marketing at any time by contacting us at PCarey@careyskens.com.
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. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
---|---|---|
To register you as a new customer | (a) Identity (b) Contact |
Performance of a contract with you |
To process your application for a loan including: (a) Manage payments, fees and charges (b) To provide you with a further loan if requested (c) Collect and recover money owed to us |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
(a) To share your personal data with CRAs before entering in to an agreement with you, PPI agencies and fraud prevention agencies detailed in section 14 of this Privacy notice. The data provided to CRAs also includes details of the payments you make under our contract and any default or failure to keep to the contractual terms. |
(a) Identity |
(a) Performance of a contract with you (b) Necessary for our legitimate interests to provide the correct loan in accordance with your financial circumstances, ensure repayments can be made as appropriate, to trace debtors, recover debts, prevent or detect money laundering and fraud, to manage your account(s) (c) Necessary to comply with a legal obligation to provide and support open and transparent lending in accordance with the Financial Conduct Authority and Consumer Credit Sourcebook (CONC) |
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or Privacy notice (b) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
To enable you to partake in a prize draw, competition or complete a survey |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
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) |
To make suggestions and recommendations to you about goods or services that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. This is why we provide you with the option to opt in, or opt out of our marketing services using the tick box on our website.
For non-website users, you can opt out of our marketing by emailing PCarey@careyskens.com or by clicking ‘opt out’ in our marketing emails.
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 and services may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or you have opted in to doing so as per the above, and you have not opted out of receiving that marketing. The marketing communications that you will receive from us will only be in relation to the services and products offered by us.
We will get your express opt-in consent again before we share your personal data with any company outside Careys for marketing purposes and will never sell your data for marketing purposes.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
In respect of our website, you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. If you would like to find our more, please see our Cookies policy.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the parties set out below for the purposes set out in the table in section 7 above:
CRAs will add the details of our search, and your application for credit, to their records. This information will be seen by other organisations making searches. This and other information about you and those with whom you are linked financially may be used to make credit decisions about you and other members of your household.
CRAs records may be shared with other organisations and may be used and searched by us and them to:
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, or their legal obligations within the financial sector.
We may search CRA records that may be linked to records relating to your spouse/partner, or other persons with whom you are linked financially and other members of your household in accordance with our legal obligation to the FCA to do so. For the purposes of any application or an agreement with you, you may be treated and financially linked and you may be assessed with reference to associated records. As a result an ‘association’ will be created which will link your financial records and your associate’s information may be taken into account when a search is carried out in future by us or another lender unless you contact credit agencies to file a disassociation. We will share your data with CRAs who will add the details of our search, and your application for credit to their records. This information will be seen by other organisations making searches. This and other information about you and those with whom you are linked financially may be used to make credit decisions about you and other members of your household.
We do not transfer your personal data outside United Kingdom
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 and to other third parties who have a business need to know (for example CRAs, PPI agencies and fraud prevention agencies). Our employees 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.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for and if you request another loan, 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.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. In brief they are the rights to:
If you wish to exercise any of the rights set out above, please contact Phil Carey immediately on 01642 850022.
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.
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.
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.
Term | Definition |
---|---|
“Lawful basis” | |
Legitimate Interest means the interest of our business in conducting and managing Careys 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. | |
Explicit Consent means processing your Sensitive Data when you have provided us with your explicit consent to do so in our consent form or verbally. | |
You can withdraw your consent at any time in the future, by emailing Pcarey@careyskens.com. Substantial public interest means processing your Sensitive Data (as defined in section 2 of this notice) only when we meet the conditions to rely on the substantial public interest exemption in Section 19, Part 2 Schedule 1 of the Data Protection Act 2018 as per section 6 of this notice (the exemption). In the absence of the exemption, we will seek your explicit consent before processing Sensitive Data as per the above. |
You may be able to borrow at a cheaper rate by contacting your local credit union. Please visit www.findyourcreditunion.co.uk for details.