SafetyNet Credit Privacy Policy This Privacy Policy has been prepared by Indigo Michael Limited, trading as SafetyNet Credit to meet the requirements of the UK's Data Protection Act 1998, (the "Act") and it only relates to the collection, protection, disclosure and use of personal data belonging to living individuals. It does not relate to data which emanates from companies or other entities, although the general principles regarding our collection and use of data is broadly the same irrespective of whoever is the user of our website, or our customers. SafetyNet Credit is registered under the Act with registration number: Z2878281 and will act as the Data Controller. This privacy policy (together with our Website Terms and Conditions of Use, available at https://www.safetynetcredit.com/Content/HTML/Terms.html and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data. 1 INFORMATION WE MAY COLLECT FROM YOU 1.1 As part of our SafetyNet Credit service and SafetyNet Credit Running Account Credit Agreement, (referred to as the SafetyNet Credit facility), you enter your internet banking details into our SafetyNet Credit Site, including your personal identification numbers (PIN) and security passwords (Internet Banking Credentials). Your Internet Banking Credentials are encrypted in transit and stored securely for a short period on our servers before being transferred to our agent and supplier Yodlee, Inc. (Yodlee). Your encrypted Internet Banking Credentials are then stored by Yodlee, upon their servers in a secure environment. 1.2 As part of SafetyNet Credit's revolving credit facility, you give us permission as your agent and nominated representative, to access, view, represent, and copy up to the last 90 days of transaction history from your nominated internet banking account, (Transaction Data). We use your Transaction Data to assess your credit worthiness, to make on-going lending and collecting decisions and, in accordance with your marketing consent preferences, to notify you of products and/or services, offered by ourselves or trusted third parties that we believe you may be interested in. Your raw Transaction Data is treated as confidential and will not be passed to any third parties. Aggregated and/or anonymised Transaction Data will only be shared with third parties with your prior consent. 1.3 For the avoidance of doubt, we will not pass your Internet Banking Credentials to any third parties. 1.4 In this Privacy Policy, where we refer to sharing information with third parties, we are not referring to sharing your Internet Banking Credentials or raw Transaction Data. 1.5 We may collect and process the following data about you: 1.5.1 Information that you may provide by filling in forms on www.safetynetcredit.com (our "Site"). This includes your name, address, email address and telephone numbers along with any other information provided at the time of your request for a revolving credit facility or requesting further services. It will also include your date of birth, residential status, time at address, employment details and financial information. We may also ask you for information when you report a problem with our Site. 1.5.2 Correspondence, or a record of it, if you should contact us. 1.5.3 Surveys that we use for research purposes, which we have asked you to complete, although you do not have to respond to them. 1.5.4 Financial transactions relating to your SafetyNet Credit facility. 1.5.5 Transaction history from your nominated internet banking account. 1.5.6 Credit reference and fraud prevention data pertaining to you and any financial associates (See also section 7). 1.5.7 Publically available information including, but not limited to, electoral roll, county court judgements, bankruptcy and insolvency information. 1.5.8 Proof of identification or details required to confirm or verify your identity, address, bank account or payment card. 1.5.9 Details of your visits to our Site (including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise) and the resources that you access. 1.5.10 Information from third parties in respect of you which may include your employer, a referee or a person residing or working from another country. 1.5.11 Any information you voluntarily provide. 2 IP ADDRESSES AND COOKIES 2.1 We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and may report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual. 2.2 A "cookie" is a small electronic file that collects information when someone visits a website. A cookie can identify the pages that are being viewed, and this can assist us to select the pages that the viewer sees. Some cookies only exist whilst viewers are online, but "persistent" cookies - which are not session-based - remain on the viewer's computer, so that he or she can be recognised as a previous visitor when he or she next visits our website. We may use persistent cookies to allow us to collect information about a viewer's browsing habits whilst on our site, so that we can monitor and improve our services. 2.3 Under the Privacy and Electronic Communications (EU Directive) Regulations 2003 (as amended) we are required to get the consent of everyone who uses our Site to the use of cookies. By continuing to use our Site you agree to the use of cookies by us in the manner outlined in this Policy and a pop up will appear on the screen when you first access the Site to remind you of this. 2.4 We do not store sensitive information such as account numbers or passwords in "persistent" cookies, and cookies in themselves do not contain enough information to identify you. We will only acquire a personal identity in relation to your browsing habits after you have formally provided us with your personal data for the purposes outlined at section 4 below. 2.5 In addition to using cookies, we might also use web tools to collect information about your browsing activities whilst on our Site. In this respect the information that is provided is similar to the information supplied by cookies, and we use it for the same purposes. 2.6 Any information that we acquire about you using cookies or web tools is subject to the same restrictions and conditions as any other information we collect about you. 2.7 Some of our advertisers may also use cookies or web tools that are set by other people such as advertising agencies, or the businesses to which the advertisements in question relate. We do not have access to any information that might be collected in this way, and, if you are concerned, you should contact the advertiser for more information. 2.8 List Of Cookies Cookie Summary Persistent/Session Description __lc.visitor_id* LiveChat Persistent This cookie is there to enable our live chat feature __utma Google Analytics Persistent This cookie is part of Google Analytics and helps us improve our customer experience by anonymously tracking how users interact our website. It is specifically used to track the number of visits to our website. __utmc Google Analytics Persistent This cookie is part of Google Analytics and helps us improve our customer experience by anonymously tracking how users interact our website. It is specifically used to check approximately how long you stay on our website. __utmz Google Analytics Persistent This cookie is part of Google Analytics and helps us improve our customer experience by anonymously tracking how users interact our website. It is used specifically to track how you arrived at our website. _vis_opt_exp* Visual Website Optimizer Persistent This cookie is used to run content experiments so we can improve the effectiveness of our website. AcceptCookies Whether to display cookie message Persistent This cookie tells us whether this is your first visit to our website and if so to display our cookie policy banner. ASP.NET_SessionId ASP.NET Session ID Session This cookie is required to make our website work by setting an anonymous ID which is used when you navigate the website. SafetyNet Credit SafetyNet Credit Campaign cookie Persistent This cookie contains information to help us understand which marketing channels are most effective and how you found our website. 2.9 Most browsers automatically accept cookies. You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our site and we cannot guarantee that your experience with our Site will be as quick or responsive. Unless you have adjusted your browser setting so that it will refuse cookies, our system will automatically issue cookies when you log on to our Site. 2.10 You can find and control your cookie settings via your browser; your browser help function will tell you how. Please note, it is not possible for SafetyNet Credit to allow you to carry your settings with you between your browsers and devices so you will need to change these settings for each browser you use. 3 WHERE WE STORE YOUR PERSONAL DATA 3.1 All information you provide to us is, as far as reasonably practicable, stored on our secure servers. Any payment transactions will be encrypted using industry standard 128-bit bank level encryption. We ask you not to permit anyone to use your SafetyNet Credit profile. 3.2 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access. 3.3 We will retain your information securely stored for a reasonable period or for as long as the law requires. 4 HOW WE USE YOUR INFORMATION 4.1 We use information held about you in the following ways: 4.1.1 to assess your creditworthiness; 4.1.2 to carry out our obligations arising from any contracts entered into between you and us including determining optimum repayment conditions; 4.1.3 in accordance with your marketing consent preferences, to notify you of products and/or services, offered by ourselves or trusted third parties that we believe you may be interested in; 4.1.4 to ensure that content from our Site is presented in the most effective manner for you and for your computer; 4.1.5 for statistical analysis and trend monitoring; and 4.1.6 to notify you about changes to our service. 4.2 We may transfer your data outside of the EEA, but only to countries that have an adequate level of protection in line with the protection afforded to the data in the UK. Please note that your data will be stored on Yodlee servers which are situated in the United States; however, Yodlee is a member of the US government ‘Safe Harbor’ scheme (go to http://safeharbor.export.gov/companyinfo.aspx?id=14108 ) The European Commission considers that personal data sent to the US under the “Safe Harbor” scheme is adequately protected to equivalent standards as prescribed by the Act. 4.3 We may also use your data, or permit carefully selected third parties to use your data, to provide you with data about goods and services which may be of interest to you, and we or they may contact you about these by post. We may receive information from a lead provider/broker, namely any third party entity which provides services or information to customers regarding the availability and terms for short term loans and which provides us with information and customer lead generation. 4.4 We may contact you by electronic methods including telephone, e-mail, or SMS, with information about services similar to those which were the subject of a previous transaction with you. We will not pass your details on to any third party to market to you by electronic methods unless we have your express consent to do so via an opt-in mechanism. 4.5 If you are not eligible for the SafetyNet Credit facility at this time, unless you opt out in accordance with clause 4.6, you agree that we may offer you an alternative product. We may also pass your details to another financial services company for them to send you details of their products in accordance with 4.3 and 4.4 above. 4.6 You may opt-out of receiving these marketing communications from us by ticking the appropriate box on the SafetyNet Credit revolving credit facility application form on our Site, at any time by responding to any of our email communications with "remove" in the subject line, by sending us an email to customer.services@safetynetmail.co.uk or writing to us at Indigo Michael Ltd t/a SafetyNet Credit, PO Box 1515, High Wycombe, HP11 9JE. 4.7 If you opt-out of our use of your data for marketing purposes, we will honour such choice once we have had a reasonable opportunity to process your request. We reserve the right to take reasonable steps to authenticate your identity with respect to any such request or other enquiry. 4.8 Any information or statistics relating to our business that we disclose to others shall not identify you personally. We may, for example, perform statistical analyses of the behaviour of the users of our Site in order to measure interest in the various areas of our site and to inform advertisers as to how many consumers have seen or "clicked" their advertising banners. This information, and any other general information about our users that we share with advertisers and other partners, will not disclose personal information about you. 5 DISCLOSURE OF YOUR INFORMATION 5.1 We may disclose your personal information to third parties: 5.1.1 To prepare or send any communications to you, or to assist us in connection with any of our administrative or business functions, or in the provision of any of our services to you. 5.1.2 If Indigo Michael Ltd or substantially all of its assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets. 5.1.3 If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions of Use https://www.safetynetcredit.com/Content/HTML/Terms.html and other agreements; or to protect the rights, property, or safety of Indigo Michael Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. 6 YOUR RIGHTS 6.1 Our site may, from time to time, contain links to and from the websites of our advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. 6.2 We will store and process your information on our computers and in any other way we consider appropriate. By "your information" we mean personal and financial information we (a) obtain from you or from third parties, such as credit reference agencies (who may search the Electoral Register), fraud prevention agencies or other organisations when you apply for an account or any other product or service or which you or they give to us at any other time or (b) learn from the way you use and manage your account(s), from your transactions and from the payments made to your account. 6.3 We will use your information to manage your account(s), give you statements and provide our services, for research, assessment and analysis (including credit and/or behaviour scoring, market and product analysis) and to develop and improve our services to you and other customers and protect our interests. 6.4 Section 7 of the Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act by sending us an email to customer.services@safetynetmail.co.uk or writing to us at Indigo Michael Ltd t/a SafetyNet Credit, PO Box 1515, High Wycombe, HP11 9JE. Any access request may be subject to a small statutory fee to meet our costs in providing you with details of the information we hold about you. 6.5 Calls between us may be recorded and/or monitored for customer service, training and general auditing purposes. 6.6 We may give information about you and how you manage your account to the following: 6.6.1 People who provide a service to us or are acting as our agents, subject to contractual or other legal obligations to keep the information confidential. If they are located in another country we will make sure that they agree to apply the same levels of protection as we are required to apply to information held in the UK and to use your information only for the purpose of providing the service to us; 6.6.2 Anyone to whom we transfer or may transfer our rights and duties. 6.6.3 We may also give out information about you if we have a duty to do so or if the law allows us to do so. 6.7 Otherwise we will keep information about you confidential. 7 Credit Reference and Fraud Prevention Agencies 7.1 When you apply for a SafetyNet facility, or other product or service you confirm that all the information you have given is true and complete. When you apply for any product or service you authorise us to check the following records about you and others: 7.1.1 our own; 7.1.2 those at credit reference agencies (CRAs); and 7.1.3 those at fraud prevention agencies (FPAs). 7.2 We will make checks such as; assessing this application for credit and we may also make periodic searches at CRAs and FPAs to manage your account with us. 7.3 If you tell us that you have a spouse or financial associate, we will link your records together so you must be sure that you have their agreement to disclose information about them. CRAs also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link. 7.4 Information on applications will be sent to CRAs and will be recorded by them. Where you borrow from us, we will give details of your SafetyNet facility and how you manage it/them to CRAs. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs and FPAs to perform similar checks and to trace your whereabouts and recover debts that you owe. Records remain on file for 6 years after they are closed, whether settled by you or defaulted. 7.5 If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies. 7.6 You can contact the CRAs currently operating in the UK; the information they hold may not be the same so it is worth contacting them all. They will charge you a small statutory fee. 7.6.1 Call Credit, Consumer Services, PO Box 491, Leeds, LS3 1WZ or call 0870 060 1414 or log on to www.callcredit.co.uk 7.6.2 Equifax plc, Credit File Advice Centre, PO Box 3001, Bradford, BD1 5US or call 0870 010 0583 or log on to www.myequifax.co.uk 7.6.3 Experian, Consumer Help Service, PO Box 8000, Nottingham NG80 7WF or call 0870241 6212 or log on to www.experian.co.uk 7.7 Law enforcement agencies may access and use this information. 7.8 We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when: 7.8.1 Checking details on applications for credit and credit related or other facilities 7.8.2 Managing credit and credit related accounts or facilities 7.8.3 Recovering debt 7.8.4 Checking details on proposals and claims for all types of insurance 7.8.5 Checking details of job applicants and employees 7.9 We and other organisations may access and use from other countries the information recorded by fraud prevention agencies. 7.10 Your data may also be used for other purposes for which you give your specific permission or, in very limited circumstances, when required by law or where permitted under the terms of the Data Protection Act 1998. 8 RESPONSIBLE LENDING 8.1 Indigo Michael Ltd is committed to responsible lending. It is important that you do not take on more borrowing than you can afford. Remember if you run into difficulties with your repayments, please contact us immediately. We reserve the right to decide for any reason that we deem appropriate to reject your application and do not have any duty or obligation to disclose to you the basis of our decision. 9 CHANGES TO OUR PRIVACY POLICY 9.1 Any changes we may make to our privacy policy in the future will be posted on this page. 10 CONTACT 10.1 Questions, comments and requests regarding this privacy policy are welcomed at customer.services@safetynetmail.co.uk or Indigo Michael Ltd t/a SafetyNet Credit, PO Box 1515, High Wycombe, HP11 9JE. If you have any concerns about the information we hold you should contact the Data Protection Officer at Indigo Michael Ltd stating what you think the problem is and you will get a response within 15 working days. If you still feel dissatisfied, you can appeal to the Managing Director of Indigo Michael Limited or you can contact the Information Commissioner's Office Customer Services Team, Wycliffe House, Water Lane, Wilmslow, SK9 5AF.