Privacy notice

About this document

This document explains who we are, what data we collect about you, how we collect that data and why we collect that data.

We reserve the right to make amendments to this privacy notice. Should we make any changes to this privacy notice they will be documented on our website. If they are significant changes we will inform you via email or sms using the records we have on file for you.

About us

For legal information about our company, the companies we own, the websites we own and the legal jurisdiction under which we operate – all of which pertain to the information on this page – please see our terms and conditions.

How to contact us

Please use one of the following methods to contact us.

Customer service and complaints

Please see the relevant section on our terms and conditions page.

Data protection/privacy

For any queries or complaints related to data protection please contact [email protected]. We will respond to your message within a maximum of 1 month. In the unlikely event that you are still dissatisfied, please contact your regional information and data protection regulator. For reference, we have included the websites of the regulators for the countries in which we operate.

1. Denmark – https://www.datatilsynet.dk/
2. Finland – https://tietosuoja.fi/
3. Norway – https://www.datatilsynet.no/
4. Sweden – https://www.imy.se/
5. United Kingdom – https://ico.org.uk/

Our responsibilities

For reference, you can find out more information about data controllers and data processors here and information about lawful basis for processing data here.

Lawful basis for processing your data

As defined by GDPR regulations, we must have a lawful basis for processing your data. We have determined that our lawful basis is “Consent”. The ICO UK defines these terms as the following:

Consent – The individual has given clear consent for you to process their personal data for a specific purpose.

Data controller

• We are the data controller for the personal information we hold about you. When submitting your information to us for the purposes of a product application, your data may be passed on to the supplier of that product. That data is passed server-to-server over a secure connection. Any data you provide to that supplier constitutes a separate agreement between you and them.
• During a disposal of assets, restructuring, merger or sale we may become a joint data controller. In situations such as these, the control of your personal data is held jointly by ourselves and the business we are engaged with.

Data transfer and storage

• Where possible, data transfer between our systems takes place using a server-to-server process. This reduces the amount of human interaction with your data. We do still use browser-to-server transfers but are in the process of phasing this out. We may occasionally need to transfer data manually via an export-import process. When that occurs, the exported data is stored in a secure, off-site location and is then deleted once the data migration is complete.
• We reserve the right to transfer your personal data to third parties in connection with a disposal of assets, restructuring, merger or sale.

You and your data

This section contains information about the kinds of data we may hold about you and how we use that data.

Your rights

1. The right to be informed
2. The right of access
3. The right to rectification
4. The right to erasure
5. The right to restrict processing
6. The right to data portability
7. The right to object
8. Rights in relation to automated decision making and profiling

How we obtain your data

Customer service communications

Customer service communications include contact forms, live chat, sms and direct email. Some or all of these methods can be found on our websites. When you submit information to us via these communication methods we need to store that information so that we can respond to your messages and find the information you may be requesting.

Cookies

We use cookies to collect fairly high-level data about you. Examples may include: your IP address, whether you have clicked on one of our adverts, geographical location, and information about your web browsing session. More information about the types of cookies and whether they are turned on or off by default can be found on our cookie notice page. You can opt in/out of some or all of these cookie categories by interacting with our cookie consent banner.

Website forms

Due to the nature of the products/services on our websites, the application forms are often the place where we collect the most data about you. These forms require you to fill in personal/business information so that our partner(s) can assess your suitability and provide you with the product/service you have requested. Examples of the data collected vary by form but could include: Name, social security number, contact details, citizenship, financial information, application purpose, application status, technical information, and – in the case of applications on behalf of a business – company name, company number, industry and number of employees. When you submit your information via these forms, we store that information in our systems before passing it on to the partner company for processing. We will always store your data when you submit the form but you are free to opt out of marketing at the time of submission. You are also free to update that consent in the future.

Telephone communications

When discussing our products/services with our telesales team we usually collect some personal data about you. The information collected is dependent on the topic of the conversation but could include: Name, contact details, citizenship, financial information, application purpose, application status, and – in the case of applications on behalf of a business – company name, company number, industry and number of employees. These calls may be recorded for training and monitoring purposes. We will always store your data in our systems but you are free to opt out of marketing during your conversation. You are also free to update that consent in the future.

What we do with your data

We retain your data so that we can:

1. Fulfil any customer service obligations we may have with you
2. Track commission payouts from our partners
3. Undertake internal analysis of market trends
4. Monitor the performance of our marketing campaigns
5. Monitor the performance of our websites
6. Send marketing communications – to customers who have opted in to receive them – via email, sms, WhatsApp Messages and telephone
7. From time to time, we may share your personal data with our selected partners.

Data retention period

Unless otherwise instructed via a data removal request, we will retain your data for 4 years from the date of your last interaction with us/our systems.

Managing your data

When you submit your information to us, we will always provide you with the opportunity to opt-in/out of our terms and conditions and privacy notice. Our forms and cookies are opt-out by default.

Once you have given cookie consent you are free to withdraw that consent at any time using the cookie consent link in the footer of our websites.

You are also free to request that your data be removed from our systems in the future via a data removal request.