Privacy Notice

Data protection law says that we can only use personal data if we have a proper reason to do so. For example, these reasons include fulfilling a contract we have with you, when we have a legal duty, when it is in our legitimate interest or when you consent to its use. When data protection law allows us to process your personal data for our own legitimate interests, it is only allowed provided those interests do not override your own interests and/ or your fundamental rights and freedoms.

An example of where we would process your personal data for our legitimate interests would be where you believe you are the victim of fraud and in order to investigate your claim we may have to share your name and account number, payment and other details of the case with any other bank involved. Sharing personal data in these circumstances would not only be in our legitimate interest but also yours. An example of us using your personal data when we have a legal duty, is where we must do so in order to comply with anti-money laundering obligations.

Our purposes for processing your personal data are grouped under our four legal bases for processing below.

A contractual obligation basis

• To consider and process applications made for products and services we provide, which may involve sharing information with credit reference agencies and fraud prevention agencies, or by other means, such as assessing information we hold about you, for instance, where we have an existing relationship with you.
• To deliver the products and services we provide, including:
  • Transferring withdrawals to your nominated account
  • Receiving repayments from your nominated account
  • Providing you with information and guidance on the products and services you hold
  • Providing statements, reminders and notices informing you of forthcoming changes, such as increasing or decreasing credit limits
  • Calculating the interest which may apply to your account
  • To address enquiries or complaints we may receive from you or a representative appointed by you
  • Assisting you with managing the products and services you hold

A legal obligation basis

• Confirm your identity
• Perform checks to detect and prevent financial crime
• Share data with credit reference agencies and fraud prevention agencies
• Comply with legal and regulatory requirements
• Where we have a duty to protect vulnerable customers

A legitimate interest basis

• Understanding how our customers use our products and services, so we can improve these
• Developing new products and services and identifying which may be of interest to you
• Sharing information with organisations who introduce you to us under a commercial agreement – for instance, where we pay them commission
• Improving our systems and processes, which may include using your personal data to test the accuracy of these, but only where it is essential to do so
• To recover money owed to us
• To invite you to participate in market research and customer surveys;
• To sell to, or purchase debts from other firms
• Sharing your personal data with any person to whom we may transfer, or may consider transferring any of our rights or business
• To share information with third parties for the purpose of preventing fraud and financial crime
• Identifying and managing risks to our business

A consent basis

Where we have the relevant permissions: contacting you to make you aware of these products and services, including sharing information with third parties who may add to this information they know about you and use this to deliver such messages to you on our behalf via social media – note: we may contact you for a reasonable period after you cease your relationship with us.

Marketing

We may use your personal data to tell you about relevant products and offers that we think you may find interesting. We can only use your personal data to send you marketing messages if you have given your consent or it is for a legitimate interest (when we have a business or commercial reason to use your information).

You can ask us to stop sending you marketing messages by contacting us at any time, although you will still receive important information, and communications of any changes, to your existing products and services.

You can change your mind and update your choices at any time by using the “unsubscribe” or “opt out” option in any marketing communication you receive from us or by contacting us at privacy@fairlo.co.uk.