Privacy notice

Last updated: 30.10.2019

Lendhub Group Limited, its subsidiaries and affiliated companies (“us”, “our”, “we” “Lendhub”) is the controller of your personal data collected pursuant to this Privacy Policy. Lendhub is committed to protecting and respecting your privacy.

Introduction

This privacy notice (the “Privacy Notice”) sets out the types of personal data we collect and how we may manage that data in order to carry out our work, including your use of our:

website: https://lendhub.co.uk (the “Website”);

application (the “App”); and products (“Products”)
and/or services (“Services”) provided via the Website and/or App.

‍

It is important that you read this Privacy Notice together with any other privacy notice or fair processing notices that we may provide at or around the time that we collect or process personal data about you (for example, fair processing notices that we may display to you at the time that you sign up to receive email updates from us) so that you are fully aware of how and why we are using that data.

This Privacy Notice supplements any other notices or terms on our Website and is not intended to override or replace them. If, for any reason, you do not agree to the terms of this Privacy Notice, please stop using our Website, App, Products or Services.

We reserve the right to revise or amend this Privacy Notice at any time to reflect changes to our business or changes in the law. When we change the Privacy Notice in a material way, we will try to let you know. However, it is your responsibility to regularly review this Privacy Notice.

The Website is not intended for children and we do not knowingly collect personal data relating to children.

What is personal data?

Where this Privacy Notice refers to ‘personal data’ it is referring to data about you from which you could be identified – such as your name, your date of birth, your contact details and even your IP address.

How is your personal data collected?

[fs-toc-omit]Direct from you or via your broker

When you register your account with us, complete an application form, request marketing be sent to you, participate in social media functions, contact us, or report a problem to us we may collect, store and use personal data that you disclose to us, which may include the following types of data:

Profile Data - which includes your username, password, security questions, and other information necessary to identify you as a registered user of our Products and/or Services.
Application Data - the information submitted about you (where you are an introducer, applicant or guarantor) when applying for a loan, which might include your name, date of birth, marital status, NI number, country of birth, nationality, length and rights of UK residency, contact details, current and previous postal address, details about the loan, details about any property being used as security, existing lender details, employment and income details, details about your assets and liabilities and credit history and your bank account details.
Technical Data – which includes browser type and version, your IP address and other technical information about the browser and device you are using.
Usage Data – which includes information about how you user our Website and/or App.

‍

[fs-toc-omit]Automated technologies or interactions

We will automatically collect your personal data including Technical Data and Usage Data. We collect this data using technologies such as cookies or other similar tracking technologies.

We use this data for several different reasons. Firstly, we use it to ensure that the Website and App works properly. Second, we use the data to monitor online traffic and audience participation across the Website and App.

Please refer to our Cookies Policy for further details.

[fs-toc-omit]Third parties or publicly available sources

We may also receive personal data about you from third parties including credit reference agencies, fraud prevention agencies, insolvency practitioners, legal advisers, debt advisers, tracing agents, commercial databases, marketing databases, public records and other publicly available information sources, including information about your business or company.

What happens if you fail to provide personal data?

Where we need to collect personal data by law, or in order to provide you with our Products and/or Services, and you fail to provide that data when requested, we may not be able to provide you with our Products and/or Services (for example, consider your loan application or offer you a loan where you did not complete all necessary fields of the application form).

The personal data you submit to us must be accurate and current. If you give us false or inaccurate information and we suspect or identify fraud, we will record this and will you’re your details on to fraud prevention agencies. If you want to update information you have previously given to us, please contact us.

Lawful basis for processing your information

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 you use our App, we will seek your consent prior to installing the App onto your device and registering you as a user of the App.

[fs-toc-omit]Performance of a contract with you

Where you have registered to use our Services or Products you enter into a contract with us. We may need process personal data in order to deliver the Services or Products to you. For example, storing your account details so that you can access your account to use of Products or Services.‍

[fs-toc-omit]Our legitimate Interests

Assess whether or not to offer you loan and the terms offered.
Manage any loan completed through to redemption in accordance with the offer and loan terms and conditions, including collection of monies due, dealing with any arrears and forbearance and taking any action, including legal action, to protect our interests.
Manage any relationship with introducers, including keeping a record of introductions, payments made and other relevant information appropriate to managing the relationship.
Manage any relationship with funders or anyone applying to become a funder and to maintain appropriate records relevant to that relationship.
To manage business relationships with our professional advisers, contractors and third party providers.
Carry out checks with fraud prevention and credit agencies and tracing agencies if required.
Review CV’s and any other material submitted to us for job applications.
To administer and protect our business and this Website and/or App including troubleshooting, data analysis and system testing.
To deliver content and advertisements to you, measure and analyse the effectiveness of the advertising we serve you and monitor trends so we can improve the Website and/or App.

[fs-toc-omit]To meet a legal or regulatory obligation

Help identify you and meet our anti-money laundering and prevention or financial crime obligations.
To comply with any request for information made by a government body, regulatory authority or law enforcement agency.

[fs-toc-omit]Marketing

‍We may use your personal data to contact you about our latest news, our Products and/or Services (we call this marketing).

You will receive marketing communications from us if you have:

subscribed to receive marketing communications from us; or
used our Services or Products, and you have not opted out of receiving that marketing when we you provide us with your email address.

‍

To unsubscribe from marketing emails at any time, please click on the unsubscribe link at the bottom of any marketing email, or you can also contact us.

We will get your express opt-in consent before we sell your personal data to any third party for its own marketing purposes.

Depending on how and why you provide us with your personal data we may share it in the following ways:

we may share your personal data with any member of our company group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
with credit reference agencies (see “Credit Reference Agency” below); and
with selected third parties who we sub-contract to provide various services (see “Service Providers” below).

‍

We may also disclose your personal data to third parties in the following events:

if we were to sell or buy any business or assets (including any debt which we decide to sell to third parties), in which case we might disclose your personal data to the prospective seller or buyer of such business or assets as part of that sale and transfer any such personal data to the seller or buyer on exchange or completion of that sale;
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or if we are asked to provide your details to a lawful authority in order to aid in the investigation of crime or disorder; and/or
in order to enforce or apply our Website or App terms and conditions, or to protect the rights, property, or safety of our company, our customers, or others.

‍

Credit Reference Agency

We use a credit reference agency to help us determine whether to offer applicants a loan and what terms.

We work closely with our selected credit reference agency to ensure that we receive a sufficiently detailed credit history about our applicants. This includes providing the credit reference agency with information about management of the loan completed through to redemption, including collection of monies due, dealing with any arrears and forbearance and taking any action, including legal action.

When we send a search request to the credit reference agency, it will place a search footprint on your credit file (or that of the relevant individual(s) connected to your business) that may be seen by other lenders. We may use this information to verify the accuracy of the information you’ve provided to us, to prevent criminal activity, fraud and money laundering, to trace and recover debts and to ensure any offers provided to you are appropriate to your circumstances.

If you inform us of financial associate(s) (this may include a spouse), we will link these records together. Please discuss this with the individual(s) and share this information with them before submitting your application. Your records (and those of individual(s) connected with your business) will also be linked by the credit reference agency and these links will remain on both files until you or the relevant individual successfully files for a disassociation with the credit reference agency to break that link.

We use CreditSafe as our credit reference agency. CreditSafe shall be an independent controller of your personal data. For more information about how Credit Safe handles your personal data please review its privacy policy:(https://www.creditsafe.com/gb/en/legal/privacy-policy.html).

Service Providers

Our service providers provide us with a variety of administrative, statistical, and technical services. We only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this data and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject. The following is a list of the type of service providers we use:

Statistical and analytics providers;
Marketing providers;
Website and App development providers;
Payment processors; and
Software security providers.

‍

Links to third-party sites

‍This Website or the App 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 links and are not responsible for their privacy statements. When you leave our Website or the App, we encourage you to read the privacy policy or notice of every site you visit.

For how long do we keep your personal data?

We will hold your personal data on our systems only for as long as required to provide you with the services you have requested, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

In some circumstances you can ask us to delete your data: see the Your Rights 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.

Security

Lendhub has put in place security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, including use of secure servers and passwords.
Where we have given you a password that enables you to access certain parts of our App, Website, Services or Products, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

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.

International Data Transfers

Whenever we do transfer your personal data outside of the European Economic Area (“EEA”), we ensure that a similar degree of protection is afforded to it by ensuring that:

we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
we will only transfer data to the US, where the business we are transferring your personal data to is part of the Privacy Shield (which requires them to provide similar protection to personal data shared between EEA and the US);
where we use certain service providers, we will use specific contracts approved by the European Commission which gives personal data the same protection it has in the EEA; and/or we are otherwise lawfully authorised to transfer your personal data outside of the EEA under applicable data protection laws.

Your Rights

As a data subject you have a number of rights in relation to your personal data.

[fs-toc-omit]Right of Access

You may, at any time, request access to the personal data we hold about you (you may have heard of this right being described as a "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.

[fs-toc-omit]Your Right to Rectification

You may request that we correct personal data that we hold about you which you believe is incorrect or inaccurate, though we may need to verify the accuracy of the new data you provide to us.

[fs-toc-omit]Your Right to Erasure

You may ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”). If for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request.

[fs-toc-omit]Your Right to Object to Processing

You may object to processing of your personal data where we rely on legitimate interest for processing that personal data. You also have the right to object where we are processing your personal data for direct marketing purposes. We will comply with your request unless we have a compelling overriding legitimate interest for processing or we need to continue processing your personal data to establish, exercise or defend a legal claim.

[fs-toc-omit]Your Right to Restrict Processing

This enables you to ask us to suspend the processing of your personal data in the following scenarios:

if you want us to establish the data's accuracy;
where our use of the data is unlawful, but you do not want us to erase it;
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
you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

[fs-toc-omit]Your Right to Portability

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.

[fs-toc-omit]Your Right to object to automated decision making and profiling

You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.

[fs-toc-omit]Your right to withdraw consent at any time

You may withdraw your 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.

[fs-toc-omit]Exercising your rights

When you write to us making a request to exercise your rights, we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.

It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information, then we may delay actioning your request until you have provided us with additional information (and where this is the case, we will tell you).

Contact Us

If you have any queries regarding this Privacy Notice, if you wish to exercise any of your rights set out above or if you think that the Privacy Notice has not been followed, please contact us by writing to info@lendhub.co.uk.

You may also lodge a complaint with our lead supervisory authority, the Information Commissioner, or you may lodge a complaint with your local supervisory authority about any aspect of our handling or processing of your personal data. We would, however, appreciate the chance to address your concerns before you approach any supervisory authority, so please contact us in the first instance.

Contents