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DIRECT LEND- PRIVACY POLICY

Direct Lend is a trading style of Technov8 Limited, a company incorporated in England & Wales (05377058) and regulated by the Financial Conduct Authority (732414). Our registered address is Technov8 Ltd, Bartle House, Oxford Court, Manchester, M23WQ.

We are a credit broker authorized and regulated by the Financial Conduct Authority. We operate under various trading styles and maintain this website. We are also registered with the Information Commissioner’s Office under registration number Z3652660.

PURPOSE OF THIS PRIVACY POLICY

This privacy policy is designed to clearly explain how we use your personal information when you visit our website seeking a financial product or service. Please read the policy thoroughly to understand what information we collect, how we use it, and how you can access, update, or delete your personal information. This policy should be read together with our Terms and Conditions, and our Cookies’ Policy.

Third-party links

If you visit a third-party website linked from ours, we are not responsible for how they handle your personal information. Please read their privacy policy to understand their practices. This privacy policy only covers how we process your personal information, excluding information in section “Our Lending Partners”, which contains the names of all members of our lending panel and provides access to the privacy policy of each one.

What is personal data?

“Personal data” refers to any data that can identify you, such as your name, address, or online identifiers like your IP address.

THE SERVICE WE PROVIDE

We use the personal information you provide when searching for a financial product or service to deliver “Our Service.” We act as a data controller for your personal information, which is stored in a UK data centre.

In order to provide you with the service, we may need to share some or all of the your personal information that you provide in your application form with a credit reference agency (CRA) to perform a soft search on you. This helps us verify your identity and creditworthiness, allowing us to determine suitable lenders for your financial situation.

We then share your personal information with our panel of lenders (“Our Partners”), who are authorized to provide the product or service you seek. If we cannot find the specific product or service, we may direct you to alternative firms offering services such as credit-building tools, which might have a monthly fee.

General information on Our Partner’s data processing purposes

Our Partners, as separate data controllers, may process your information for their legitimate interests in determining whether they can provide the financial service or product you need. For example, if you’re inquiring about a loan, Our Partners include lenders and credit brokers who operate their panels of lenders and brokers. They will assess your loan eligibility and perform a soft search.

If Our Partners cannot help you, they may retain your personal information for a period (usually 12 months) to fulfil legal and regulatory obligations and legitimate interests, such as fraud and credit analysis. This also prevents unnecessary credit searches during subsequent applications.

If your initial loan search is unsuccessful, we may offer you the option to connect your bank or building society account through one of Our Partners to validate your income. This may increase your chances of obtaining a loan, as lenders will have access to your recent transactional data and better assess your creditworthiness. Alternatively, we may offer you the option to consent to sharing your personal information with one of Our Partners who provide debt solution products and allow them to contact you by phone or SMS for debt management assistance. If you do not consent, you can choose to proceed with a different financial product or service from one of Our Partners that we think may be of interest to you, such as a guarantor loan, debt solution, or banking product. In this case, we will share your personal information with Our Partner for their assessment.

Loan applications

If your loan search is successful, you will be redirected to Our Partner’s website to complete your application or presented with eligible offers for products and services. If you proceed with any offers, you will be redirected to Our Partner’s website to complete your application.

Our Partner will provide you with the loan product’s terms and conditions. If you decide to complete your application, they will perform their identification and validation checks (including fraud prevention, affordability, and credit application checks) according to their criteria. Any full credit check (or “hard” search) carried out by Our Partners will be visible on your credit file to other lenders in the future.

Credit card inquiries

For credit card inquiries, we will share your information with our pre-screening and eligibility checking service providers and certain panel members of credit card issuers (“Our Providers”). They will conduct soft searches and eligibility checks without impacting your credit rating.

Our Providers will use their internal databases, scoring methods, and knowledge of acceptance criteria to determine your likelihood of being accepted.

You will be presented with credit cards you may be eligible for, and you can apply directly with one of Our Partners. If you do so, we will share your information with Our Partner, and you will be redirected to their website to complete your application.

Our Partner will provide you with the terms and conditions for the credit card you are applying for. If you decide to complete your application, they will also perform their identification and validation checks (including fraud prevention, affordability, and credit application checks) according to their criteria. Any full credit check (or “hard” search) carried out by Our Partners will be visible on your credit file to other lenders in the future.

Debt Help inquiries

For debt help inquiries, we will assess your financial situation and share this information with one of Our Partners to determine if they can assist you. If so, they will contact you to discuss the most suitable debt solution product for your needs. They will perform an income and expenditure assessment, identification, and validation checks (including fraud prevention, affordability, and credit checks) according to their criteria. Any full credit check (or “hard” search) will be visible on your credit file to any lender or other financial services firm in the future.

Before completing and submitting any application on one of Our Partner’s sites, you should read their privacy policy to ensure you understand how they will process your personal information. We are not responsible for how any of Our Partners handle your personal information.

We will stay in contact with you regarding your inquiry for example, by emailing or texting your results or confirming any “next steps”) and about similar products and services we offer (unless you have opted out) using the contact details you have provided to us. If you are redirected to or click a link that takes you to a third-party website that is not ours, we will not be responsible for how they use your personal information. You should read their privacy policy to understand how they may use your personal information.

COLLECTING & STORING YOUR PERSONAL INFORMATION

Purposes of Processing and legal basis

The table below describes the most common scenarios in which we will need to use your personal data and a description of the legal basis that we rely on in order to process each category of personal data. There can be more than one legitimate ground for processing for the same purpose (for example: we may rely both in your consent and in our duty of care or contractual duty to you, in order to process your information).  If you have any questions about our data processing practices, please do not hesitate to contact us.

Purpose/Activity

Type of Data

Lawful Basis for Processing

Matching with Appropriate Partners

a) Identity information

b) Contact information

c) Financial information

d) Employment information

e) CRA information

f) General information

a)Necessary for the fulfilment of our contractual obligations to you (the provision of our credit broking service)

b)Necessary for our legitimate interests (operating and improving our business)

Consent for Sharing with the Lending Panel

(“Our Partners”)

a) Identity information

b) Contact information

c) Financial information

d) Employment information

e) CRA information

f) General information

a) Consent

b) Necessary for the fulfilment of our contractual obligations to you (the provision of our credit broking service)

Assessing Product or Service Eligibility

a) Identity information

b) Contact information

c) Financial information

d) Employment information

e) CRA information

f) General information

a)Necessary for our legitimate interests (operating our business and improving our services)

b) Necessary for the fulfilment of our contractual obligations to you (the provision of our credit broking service)

Communicating with You

a) Identity information

b) Contact information

c) Marketing and communications information

a) Necessary for our legitimate interests (operating our business and improving our services)

b) Necessary to comply with a legal obligation or regulation standard

c) Consent

Profiling and Advertising

a) Identity information

b) Contact information

c) Financial information

d) Marketing and communications information

e) Technical information

f) CRA information

a) Necessary for our legitimate interests (improving our business and product relevance)

b) Necessary to comply with a legal obligation or regulation standard

Improving Services and Sharing with CRAs

a) Identity information

b) Contact information

c) Financial information,

d) Employment information

e) General information

f) Marketing and Communications information

Necessary for our legitimate interests (to categorize customer segments for our offerings, maintain a current and engaging website, expand our business, and enhance our marketing approach)

Data Retention

In accordance with the United Kingdom’s data protection laws and regulations, we aim to keep personal data for no more than 12 months from the day you either stop using our service, or request us to erase your information from our databases. However, please note that there may be circumstances in which the law requires regulated entities to keep a consumer’s personal data for a different period of time. You always have the right to know what the status of the data is retained by us. Please see ‘Your Rights under the GDPR’ for more information.

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

We understand that your personal information is sensitive and private, and we are committed to protecting it. We want to be transparent about how we use your personal information and with whom we share it. When you use Our Service, we may need to share your personal information with certain third parties or categories of third party, as detailed below.

Our Partners  & Collaborating Entities

We work with a range of partners to help you find the financial product or service you are looking for. Our partners may include lenders, brokers, and credit card issuers, as well as firms who provide credit broking, credit information services, e-money issuance, and payment services. If you are enquiring about help with your debts, our partners may include debt management companies.

In order to assist you in locating the financial product or service you are seeking through our website and to provide you with marketing communications (if you have granted consent), we collaborate with a variety of partners. For those searching for loans or credit card products, our partners include a selection of consumer credit lenders, brokers, and reputable financial service providers. These include but are not limited to the following partners: Express Finance Loans Ltd, Savvy.co.uk a trading name of Valour Finance Limited, Automotive online trading as Quick Car Finance and Hotkeyhub Limited, BlackB Financial Services Ltd Trading as The Financial Insider.

In the event that you are unsuccessful in your search for a loan or credit card, our collaborating entities include financial service firms that, when necessary, possess the appropriate authorization and regulation from the Financial Conduct Authority. These firms provide services such as credit broking, credit information services, e-money issuance, and payment services, and can offer a diverse array of alternative financial products and services, including, for instance, a variety of credit reporting tools.

We will share your personal information with our partners to help you find the most suitable product or service, and to send you marketing communications if you have given us your consent to do so. We will always ensure that our partners handle your data securely and in accordance with the UK GDPR and other UK privacy legislation.

Our Providers

When you check your eligibility for a credit card through our site, we may need to share the information you provide to us with providers of pre-screening and eligibility checking services. We will always ensure that these providers handle your data securely and in accordance with the UK General Data Protection Regulation 2016 (“UK GDPR”) and other UK privacy legislation. If you wish to know more about how these providers handle your data, you can find their privacy notices on their individual websites.

Credit Reference Agencies

To help us improve Our Service, we occasionally share customer personal information with credit reference agencies (CRAs). CRAs aggregate this information so that no one can be identified, allowing us to analyze patterns and trends that help us identify the most appropriate product or service for you, and to show you relevant adverts that may be of interest to you. We may also share your information with CRAs to process your application, check your identity and creditworthiness, and assess which of our partners may be more suitable for your financial circumstances.

Government Agencies or Regulators

We will share your personal information with appropriate government agencies when we have your consent or when we are obliged to do so for legal or regulatory reasons, such as to prevent or detect crime, for compliance monitoring, or to enforce our terms and conditions and other agreements.

In connection to structural business changes

If we sell, transfer, or merge parts of our business or our assets, we may also share your personal information with any third parties involved in the sale, transfer, or merger. If this happens, the new owners may use your personal information in the same way as set out in this privacy policy.

Automated Decision Making

We do not make automated decisions about you. However, some of our partners may use automated decision-making processes when we share your personal information with them to assess your eligibility for Our Service. If you ask us, we can tell you which of our partners has made an automated decision about you. You also have the right to ask our partners not to make a final decision based solely on automated means and to ask that a person reviews it. If you wish to exercise this right, you will need to contact our partners directly.

Other Third Parties

We may also share your personal information with other third parties who enable us to provide Our Service, such as IT service providers, communication providers, and marketing data analysis providers. These third parties help us provide Our Service, and we will ensure that they handle your data securely and in accordance with the UK GDPR and other UK privacy legislation.

INTERNATIONAL DATA TRANSFERS

So that we can provide and maintain our Service, your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be accessed by and transferred to — and/or stored on — computers and by staff located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. Despite any differences in the regional or national laws, we will, in all circumstances, safeguard personal data as set out in this Privacy Policy.

Our business currently operates within the UK and the European Union. However, should we have to transfer personal data from the European Economic Area to a country outside the EEA (or a country that is NOT considered as offering an adequate level of protection as adopted by the European Commission, Art. 45 of the GDPR), additional measures will be in place to safeguard the relevant personal data. Such transfer will be based on legal grounds and mechanisms justifying such transfer, such as EU Commission-approved standard contractual clauses, or other legal grounds permitted by applicable law, unless exempted by an adequacy decision (http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm). Please contact our Data Protection Officer on the contact details set out in this Privacy Notice if you want further information on the specific mechanism used by us if we ever need transferring your personal data out of the EEA.

DATA SECURITY

We take the security of your personal information seriously and have implemented appropriate measures to prevent its accidental loss, unauthorized use, access, alteration, or disclosure. We ensure that access to your personal information is limited to employees, agents, contractors, and third parties who have a legitimate business need to access it. These individuals will only process your personal information on our instructions and are bound by a duty of confidentiality.

In the event of a suspected personal data breach, we have established procedures to address the issue promptly. We will notify you and the relevant regulator of any data breach, as required by law.

HOW TO ACCESS AND CONTROL YOUR PERSONAL DATA
You  have the right to access all information held about them to ensure that their personal data is accurate and relevant for the business purposes for which it was collected. Data protection legislation gives you, the data subject, various rights in relation to your personal data that we hold and process. Those rights are, in the main, set out in Articles 12–23 of the UK/EU GDPR:

  1. Right to be informed: Individuals have the right to be informed about the collection, use, and sharing of their personal data.
  2. Right of access: Individuals have the right to access their personal data and obtain copies of it.
  3. Right to rectification: Individuals have the right to correct or update their personal data if it is inaccurate or incomplete.
  4. Right to erasure: Individuals have the right to request the erasure of their personal data under certain circumstances, such as when it is no longer necessary for the purpose for which it was collected.
  5. Right to restrict processing: Individuals have the right to request that their personal data is not processed in certain ways, such as for marketing purposes.
  6. Right to data portability: Individuals have the right to receive their personal data in a structured, commonly used, and machine-readable format and to transfer it to another controller.
  7. Right to object: Individuals have the right to object to the processing of their personal data in certain circumstances, such as for direct marketing.
  8. Rights related to automated decision-making: Individuals have the right to request human intervention in decisions made solely by automated means, such as profiling.

If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, you can contact us:

  • by post at: Data Protection Officer, Technov8 Ltd, Bartle House, Oxford Court, Manchester, M23WQ.
  • by email at: dataprivacy@technov8.com

We may need to request specific information from you to help confirm your identity and ensure your right to access the information. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

We will 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, but we will always comply with Subject Access Request’ timeframes recommended by the authorities.

You also 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 THIS PRIVACY STATEMENT

This privacy policy is current and accurately reflects Technov8 Limited’s data handling practices. Please note that the terms and provisions of this privacy policy may be changed, updated and amended from time to time. These changes can arise, among other reasons, due to changes in legislation or our own business operational changes. We encourage you to check this page regularly, as changes can be introduced without notice.