Who
is Salary Finance?
When
we refer to “Salary Finance”, “we”, “our” or “us” in these Terms,
we mean Salary Finance Limited and each of its group companies (including parent, subsidiary
and joint venture undertakings).
Salary
Finance Limited and Salary Finance Loans Limited are authorised and regulated by the Financial
Conduct Authority (firm reference numbers: 758053 and 734585). Salary Finance Limited is registered as
a small payment institution money remittance firm (firm reference number: 788485).
For loan products, depending on the employer, Salary Finance Limited acts either as lender, or credit
broker exclusively for associated company Salary Finance Loans Limited.
The “Advance” product is not a regulated lending product.
Salary Finance Limited and Salary Finance Loans Limited are registered in England & Wales
(company numbers: 09677777 and 07643748) at registered address One Hammersmith Broadway, London, W6 9DL.
Salary Finance Limited and Salary Finance Loans Limited are registered with the Information Commissioner’s Office under numbers ZA152606 and ZA099501.
Availability of all of our products and/or services is within our sole discretion. Not all of our products and/or services are available to all users.
You
can find out more about
Salary Finance on our website
.
This
Privacy Policy
This Privacy Policy sets out how we collect your personal data and how we use it.
It applies to all of our products:
●
Loans repayable by salary deduction (“Borrow”);
●
Salary deduction for savings accounts with Yorkshire Building Society, including (Jars
(as defined below)) (collectively referred to as “Save”);
●
Advances of accrue earnings (“Advance”);
●
Salary deduction for savings accounts with Yorkshire Building Society and NEST pensions ("Salary Deduction for HtS"); and
●
Salary deduction for savings accounts with Yorkshire Building Society and NEST pensions (“Jars”)
How you can contact us
If
there’s anything you’re unsure about in this Privacy Policy, feel free to
contact our data protection officer at
hello@salaryfinance.com
.
Table of Contents
-
1.
What information we collect and from where
-
1.1. Summary
-
1.2. Further Details
-
1.2.1. Contact information
-
1.2.2.
Employment information
-
1.2.3.
Sensitive Data
-
1.2.4.
Eligibility Information
-
1.2.5.
Bank account information
-
1.2.6.
Information provided to our savings provider (Yorkshire Building Society)
-
1.2.7.
Information provided to and from HMRC and NS&I where you are a Salary Deduction for HtS customer
-
1.2.8.
Information about your behaviour
-
1.2.9.
Credit reference agencies and electoral roll
-
1.2.10.
Website usage
-
1.2.11.
Recording our calls
-
2.How we use your information
-
2.1. Summary
-
2.2. Further Details
-
2.2.1.
To validate your identity and authenticate the information you provide
-
2.2.2.
To set up a Direct Debit
-
2.2.3.
To enforce our terms and conditions
-
2.2.4.
To provide and improve customer support and experience
-
2.2.5.
To process payments and collect arrears
-
2.2.6.
To personalise website experience
-
2.2.7.
Research purposes
-
2.2.8.
Administration of prize draws, competitions, customer offers, surveys and other promotional activities
-
2.2.9.
Marketing (including electronic marketing)
-
2.2.10.
Crime or fraud investigation, detection and prevention
-
2.2.11.
Reporting and analytical purposes
-
2.2.12.
To maintain our records and other administrative functions
-
2.2.13.
Complaint and dispute resolution
-
2.2.14.
To comply with the law
-
2.2.15.
To inform you about significant changes to our products, their terms or our Privacy Policy.
-
3. The lawful basis for our collection of personal information
-
3.1. Summary
-
3.2. Further Details
-
3.2.1. Performance of contract or to comply with law
-
3.2.2. Legitimate interests
-
3.2.3. Consent
-
4. Who do we share and disclose your personal information with?
-
4.1. Summary
-
4.2. FurtherDetails
-
4.2.1 We may share your personal information with the following third parties.
-
5. Using other websites.
-
6. Where in the world we send information.
-
7. How long we keep your personal information for.
-
8. Automated decision-making.
-
9. How we process your data for the purpose of fraud prevention and detection.
-
9.1. Summary
-
9.2. Further Details
-
9.2.1. General
-
9.2.2. Automated Decision
-
9.2.3. Consequences of processing
-
9.2.4. Data transfers
-
9.2.5. Your rights
-
10. Your rights in respect of the processing
-
11. Security
-
12. How to make a complaint about the use of your data
-
13. Changes to this Privacy Policy
1. What information we collect and from where
1.1. Summary:
We
will need to ask you, and your employer or any membership organisation (as
applicable) and our savings provider (where you have a savings product with
us), for certain personal information to provide you with the best possible
experience when you engage with us (via our websites or otherwise) and when you
use our products and/or services. We also work with certain organisations
(“External Organisations”), including Yorkshire Building Society (in relation
to Save and Jars) and HM Revenue & Customs (“HMRC”) (which is the part of HM
Government responsible for Help to Save) and National Savings & Investments
(“NS&I”) (in relation to Salary Deduction for HtS) and will seek certain information
about you from such External Organisation in order to provide you with the relevant
products/services you have applied for.
In relation to Borrow, we will also collect information about you from credit reference
agencies (CRAs) to make sure that any Salary Finance products and/or services are affordable
to you and suitable for your needs and to manage your account.
(see our Cookie Policy for details).
We
will also collect other information about you and the devices you use to access our websites,
or we may ask third parties to do this for us, using technologies such as cookies.
We
may collect any personal information which you provide to us voluntarily, for
example by completing a form on any of our websites or in hard copy, by taking
part in a survey or competition, a phone conversation or by emailing us.
Where
we seek information from you, giving this information is your choice and if you
choose not to give all or some of it to us, this may affect our ability to
provide you with the products and/or services you require.
1.2. Further details:
The
information that we may collect about you is set out below. The personal
information that we collect about you depends on various factors, including the
products and/or services you apply for and use (for example, loan or savings
products), the method of loan repayment we put in place for you and whether you
choose to take part in surveys, competitions etc.
Contact
information
When
you apply for Salary Finance products and/or services we will ask you to
provide some contact information, which may include some or all of the
following: full name, residential address, telephone number and email address.
We
may also ask third parties (such as your employer, a CRA or our savings
provider (if applicable)) for this information to confirm that the information
that you provide us with is correct (and remains correct from time to time) or
to contact you for the reasons set out below (where we have a lawful basis to
do so).
Employment information
When
you apply for Salary Finance products and/or services we will ask you to
provide some information about your employment, which may include some or all
of the following: job title, work start date, gross annual income (and any
other employment income), previous period net pay, payroll/employee ID number
(and, if applicable, national insurance number, or any other form a
personal identifier) and current or anticipated employment status
(for example, active, leaver, sick leave, maternity/adoption/parental leave,
redundancy).
When
you register for Advance (if this is available to you), we will obtain details of how you are paid, such as how your salary is accrued
and whether it is paid to you in arrears.
We
may also ask third parties (such as your employer or a CRA) for this
information to confirm that the information that you provide us with is correct
(and remains correct from time to time).
Sensitive
data
We
may ask you or third parties (such as your employer or a CRA) for information
relating to your employment status (including health and redundancy) as this
may affect your ability to perform the obligations you owe to us.
Eligibility
information
When
you apply for Salary Finance products and/or services we will ask you to
provide information to help us (in addition to the above) to assess your
eligibility and suitability for Salary Finance products and/or services. This
may include some or all of the following: address history, residential status,
date of birth, partner’s income, number of dependents.
We
may also ask third parties (such as your employer or a CRA) for this
information to confirm that the information that you provided us with is
correct (and remains correct from time to time).
Bank
account information
Where
you have been accepted for a Salary Finance loan, we will ask you to provide
your bank account details so that we know where to send your loan funds and
also to allow us collect repayments via Direct Debit if making loan repayments
from your salary is not possible (whether because your employer does not
support repayments by salary deduction or because you have left your employer
or otherwise).
When
you register for Advance (if this is available to you), we will ask you to provide your bank account details and
other associated details to allow us to validate the bank account to which your
earnings are paid.
When
you register for Salary Deduction for Hts (if this is available to you), we will ask you to provide your bank account details so that,
if NS&I are not able to credit your Help to Save account with the amounts deducted from your earnings ("Deductions"), we can return
the Deductions (or the difference between the Deduction and the amount credited to your Help to Save account) to you.
We may also share your bank details with HMRC and NS&I in order to set up a Help to Save account on your behalf.
When you register for Save or Jars (if this is available to you), we will ask you to provide your bank account details so that,
if we are unable to credit your Yorkshire Building Society account with the Deductions, we can return the Deductions (or the
difference between the Deduction and the amount credited to your Yorkshire Building Society account) to you.
Information
provided to our savings provider (Yorkshire Building Society)
Where
you have Save or Jars, we will ask our savings provider for details that they hold about you which may include some or all of the
following: title, forename(s), surname, date of birth, address, email, phone number, account number and sort code and other details
about your savings account (including account close date, inactive date, balance).
Information
provided to and from HMRC and NS&I where you are a Salary Deduction for HtS customer
HMRC (and/or NS&I) will provide us with data required for Salary Deduction to HtS,
which may include one or more of the following: your first and last name, date of birth,
whether or not you are eligible for an NS&I Help to Save account and details about
your NS&I Help to Save account, including your account number, headroom, account status,
current balance, any restrictions on adding funds and (if applicable) your bonus estimate.
In order to help you set up a Help to Save account, we will provude HMRC with data required
for Salary Deduction to HtS, which may include one or more of the following: your email
address and bank account details.
We will transfer Deductions to NS&I to be credited to your Help to Save (subject to Help
to Save account rules, including limits that may be credited each month).
Information
about your behaviour
We
collect information about your behaviour in relation to your obligations under
our products and/or services - for example, whether you make repayments on
time.
Credit
reference agencies (CRA) and electoral roll
In relation to Borrow, as
a responsible lender, we perform automated soft credit searches with CRAs to
check your credit history. We access this data from CRAs (whether in the UK or
any other country). This may include (but is not limited to) some or all of the
following: details of credit accounts held and repayment performance, as well
as public information such as inclusion on the electoral roll, bankruptcies and
county court judgements. The CRAs will record our searches.
The CRA we use is TransUnion who can be contacted via their website.
See TransUnion’s privacy policy here
Website
usage
Our
website may use cookies to store information about your site usage. A cookie is
a small text file that is sent to your browser from a web server and then
stored on your hard drive. Please see our Cookie Policy here
for further details of how we use cookies and how to disable them.
Recording
our calls
We
may record and monitor our telephone calls to help improve the products and/or
services we provide to you.
Responses
to prize draws, competitions, customer offers, surveys and other promotional
activities
We
may also record information that we obtain from you (or third parties) from
prize draws, competitions, customer offers, surveys or other promotional
activities that you take part in.
2. How we use your information
Summary
We
use your personal information in a number of ways to fulfil your request and
make our products and/or services as effective as possible. We only retain your
data for as long as is necessary and for the purposes specified in this policy.
Further details:
We
may use any of the information we collect about you for any of the following
purposes (as well as for the reasons set out above).
To
enable you to apply for, and to use, our products and/or services
We
will use your information to register you as a user and to provide you with our
products and/or services. This includes, for example, using your information:
●
to contact you about your application
and the products and/or services you have with us;
●
to verify your eligibility and
suitability for our products and/or services;
●
to decide whether to offer you our
products and/or services;
●
in relation to Borrow, to search CRA records;
●
to enhance the accuracy of information we hold and which
your employer or membership organisation (as applicable), and (if applicable)
their outsourced payroll providers, holds about you;
●
to make payments, on your behalf, to
your third party creditors (where you are using our direct debt consolidation
service);
●
to advise the payroll team of your
employer or membership organisation (as applicable) of your registration;
●
to manage your account;
●
in relation to Borrow, to
determine the method by which your loan repayments will be collected;
●
in relation to Borrow, to
administer the disbursal of loan repayments and the collection of loan
repayments (whether by salary deduction or otherwise);
●
where you have Advance (if this is available to you), to administer
the disbursal of payments, make adjustments to the earnings you receive on your
usual pay day and determine the method of collecting any payments that you’re not entitled
to but that may have been paid to you;
●
where you have Save, to
share relevant data about you with our savings provider so that we can
reconcile data that they hold about you with data that we hold about you;
●
where you have Save including Jars, to share relevant data about you with our savings
provider so that we can reconcile data that they hold about you with data that we hold about you;
●
where you have Save including Jars, to administer collections of savings deducted from your salary; and
●
where you have Salary Deduction for HtS (if this is available to you),
to help you set up a Help to Save account (if you don't already have one),
to link your Help to Save account with your Salary Finance account, to
administer the transfer of funds from your earnings to your HtS account
and to provide you with details about your Help to Save account.
To validate your identity and
authenticate the information you provide
We
will confirm your identity and authenticate the information you provide for
security purposes.
To send and receive
information about your credit history and to carry out other background checks
In relation to Borrow, we will send information
about you to and from one or more CRAs. This is to help to verify whether our
products and/or services are suitable for you and to run appropriate fraud,
anti-money laundering or background checks. We may tell CRAs how you run your
relationship with us, including whether or not you make your loan repayments on
time, if you default on your loan or enter into any repayment arrangements.
This reporting may make obtaining future credit more difficult.
To set up a Direct
Debit
We
will use your information to set up a Direct Debit with your bank account in
order for us to collect repayments of loans you have with us.
To
enforce our terms and conditions
We
will use your information to enforce the terms and conditions that are accepted
by you when you apply for Salary Finance products and/or services.
To
provide and improve customer support
We
will use your information to be able to provide and improve the customer
support we provide to you (for example, queries about our products/services,
access/log-in, account management etc.).
To
process payments and collect arrears
We
will use your information to process the payments you commit to when signing up
to our products/services and for the collection of any future payments or
overdue amounts for those services.
To
personalise website experience
Salary
Finance may use your data to monitor and to enable website personalisation and
improve your online experience.
Research
purposes
Salary
Finance will use your information for internal research purposes, general
website administration, demographic and statistical analysis of our service
users. For example, we may use cookies and analytical software to collect
anonymous data for internal research purposes.
We
may use your data to generate non-personal statistical data, for example
relating to the size of our customer base, the levels of site usage and customer
behaviour. This will only be group data, such as the age range of site users, and
will not include any information that could personally identify you. This may then
be shared with third-parties and your employer or membership organisation
(as applicable) and (if applicable) their outsourced payroll providers.
Salary
Finance may ask particular customers to participate in market research (for
example, a survey or a questionnaire). If you accept this invitation, we will
use the feedback you give us to improve our products and services and/or other
research purposes.
Administration
of prize draws, competitions, customer offers, surveys and other promotional
activities
From
time to time, we will run prize draws, competitions, promotions and surveys
and, we will use the information you provide to us, to run such activities
(including contacting you to see if you want to take part) and to do what we agree to do as part of them.
Marketing
(including electronic marketing)
We
will use your information for marketing purposes to keep you informed of any of
our products, services or offers, or those of our third party partners, that
may interest you. We or they may contact you about them (including by post,
email or SMS).
You
can opt out of marketing communications at any time by emailing
hello@salaryfinance.com
or by clicking the unsubscribe link in any marketing
email you receive from us.
Where
we are required by law to obtain your consent to use your personal information
for marketing purposes, we will ask for this consent separately and clearly.
Crime or fraud
investigation, detection and prevention
We may use your information for the
investigation, detection and prevention of crime and/or where we feel that it
is a necessary action to protect the property, rights or safety of Salary
Finance or any other party, and/or to provide suitable security for your
account and the information that we hold about you.
Reporting and analytical purposes
We will use your information for
reporting and analytical purposes to meet our legal, regulatory and contractual
obligations to enable us to improve our products and services and to provide
appropriate levels of support to our customers.
To maintain our records and
other administrative functions
Salary Finance needs to ensure that it
maintains comprehensive and up-to-date and accurate records of the ways we
process your personal information and other operational activities and
therefore we will process the information you provide for record-keeping and
general administrative purposes.
Complaint and dispute
resolution
Whilst we will try to make sure that you
are satisfied with the service we provide, if you do complain to us, we will
use the information we have about you to help us manage your complaint.
To comply with the law
We are required to comply with many laws
and regulations. We will, where necessary, use your personal data to the extent
required to enable us to comply with these requirements.
To
inform you about significant changes to our products, their terms or our
Privacy Policy.
We
may notify you if there are significant changes to our products, their features
or their terms or to our Privacy Policy.
3. The
lawful basis for our collection of personal information
Summary:
Where we process your personal
information, we will ensure that we have a lawful basis to do so.
Further details:
Performance
of contract or to comply with law
We
may rely on this basis for processing personal information where the processing
is necessary for the performance of a contract to which you are a party or in
order to take steps at your request prior to entering into a contract, or for
compliance with a legal obligation to which we are subject. Failure to provide
personal data for these purposes may mean that we cannot perform the services
requested or you may not be able to use the products and/or services we offer.
We
may rely on this basis for processing where we process personal information for
the following purposes:
●
to enable you to apply for, and to use,
our products and/or services (for example, entering into a consumer credit
agreement or the terms and conditions of our savings provider);
●
to validate your identity and
authenticate the information you provide;
●
to send and receive information about
your credit history;
●
to set up a Direct Debit;
●
to enforce our terms and conditions;
●
to provide and improve customer support;
●
to process payments and collect arrears;
●
to personalise website experience;
●
crime or fraud investigation, detection
and prevention;
●
reporting and analytical purposes;
●
to maintain our records and other
administrative functions;
●
complaint and dispute resolution;
●
to comply with the law; or
●
to inform you about significant changes
to our products, their terms or our Privacy Policy.
Legitimate
interests
We may rely on this basis to process
personal information where the processing is necessary for the purposes of
legitimate interests pursued by us (or by a third party) (except where such
interests are overridden by your interests or your fundamental rights and
freedoms).
We
may rely on this basis for processing where we believe that processing the data
has the following benefits:
●
to enable you to apply for, and to use,
our products and/or services (for example, entering into a consumer credit
agreement);
●
to validate your identity and
authenticate the information you provide;
●
to send and receive information about
your credit history;
●
to set up a Direct Debit;
●
to enforce our terms and conditions;
●
to provide and improve customer support;
●
to process payments and collect arrears;
●
to personalise website experience;
●
research purposes;
●
administration of prize draws,
competitions, customer offers, surveys and other promotional activities;
●
marketing (including electronic
marketing);
●
crime or fraud investigation, detection
and prevention;
●
reporting and analytical purposes;
●
to maintain our records and other
administrative functions;
●
complaint and dispute resolution;
●
to comply with the law; or
●
to inform you about significant changes
to our products, their terms or our Privacy Policy.
Consent
We
may also rely on you providing consent to our processing in the following
scenarios:
●
internal research purposes;
●
administration of prize draws, competitions,
offers, surveys and other promotional activities;
●
marketing (including electronic
marketing); and
●
obtaining and using sensitive data.
If
you choose not to give your consent, or you later remove your consent, this may
affect our ability to provide the services you want to you.
Where
we are required to obtain your consent by law, we will ask for this consent
separately and clearly.
4. Who
do we share and disclose your personal information with?
Summary:
We
will share your information with various third parties for the purposes set out
above (and where Salary Finance has a lawful basis to do so).
Further details:
We
may share your personal information with the following third parties.
Employers
or membership organisations
We may share relevant information
(such as contact details, date of birth, gross basic annual salary, previous
period net pay, start date of your employment, payroll or membership number,
and any product-specific orders which are to be processed via payroll) with
your employer or membership organisation (as applicable), and (if applicable)
their outsourced payroll providers, in order to improve the accuracy of our
respective records and to determine the method by which you loan should be
repaid (if you are a Borrow customer).
Suppliers and External Organisations
We
may share your personal information with suppliers who provide services to us
and who require access to your personal information in order to process it for
the reasons set out above.
Our
suppliers include:
●
brokers, lenders and providers of credit
and financial products; and
●
IT providers (such as communications
management providers or suppliers that assist with user monitoring).
Group
companies
We
also share your personal information with companies within our group, or our
business partners, who manage some parts of our products and/or services.
Regulatory
and law enforcement bodies
We
may also provide personal information to fraud prevention agencies, public
bodies, law enforcement bodies and other judicial or regulatory bodies.
Professional
bodies
We
may also share your personal data with third parties where such third parties
are acting in a professional capacity, for example an auditor, and there are
appropriate confidentiality and privacy measures in place.
CRAs
In relation to Borrow,
we may share your personal information with CRAs. We also report default
or repayment arrangements to the CRA. This reporting may make obtaining
future credit more difficult.
Introducers
We
may share your personal information with introducers, brokers or financial
advisers you may have engaged on your behalf.
Jars
In relation to Jars, we may share your information with the National Employment
Savings Trust Corporation for the purpose of conducting surveys. We will only
share this information where you have given us your consent. If you wish to
withdraw your consent, please let us know at hello@salaryfinance.com
5. Using
other websites
Our
websites may contain links to websites which are owned or controlled by parties
other than Salary Finance. These links are provided for your convenience and do
not imply that we have reviewed or condone the third-party sites, their content
or their privacy policies.
When
using other websites you must be aware that any personal information you supply
will be dealt with in line with their privacy policies. This Privacy Policy
only applies to this website so when you click through to other websites you
should read their own privacy policies and terms and conditions before giving
them any of your personal information.
Our
website may also automatically transfer you to a third party site in order to
fulfil the services we provide to you. In such cases, we will carry out due
diligence to ensure third parties have the appropriate data protection
requirements in place.
When
you access linked third party websites, you do so at your own risk. These sites
may place their own cookies or other files on your computer, collect data or
solicit personal information from you. We will not be held liable for any
misuse of your information or other misconduct by the third party.
6. Where
in the world we send information
Salary
Finance Limited is based in the UK, and this is where we operate our software platform,
however in order to provide you with a great service a reduced subset of your
personal information may be transferred outside the European Economic Area
(EEA) to make use of services that operate outside the EEA. Any personal
information we access or transfer to these locations is protected by European
data protection standards.
To make sure we keep your personal
information safe, we apply strict safeguards when transferring it overseas. For
example, transfers to the United States of America will be subject to
appropriate additional safeguards under the EU-US Privacy Shield Framework.
For further information about these safeguards, please contact our Data
Protection Officer at hello@salaryfinance.com
7. How
long we keep your personal information for
We’ll
keep your personal information for as long as is necessary for the purposes
specified in this Privacy Policy. The criteria that we use to determine the
period for which we retain personal information include:
●
legal and regulatory requirements and
guidance;
●
limitation periods that apply in respect
of taking legal action;
●
our ability to defend ourselves against
legal claims and complaints;
●
good practice; and
●
the operational requirements of our
business.
These
reasons vary from one piece of information to the next depending on the
products and/or services you have signed up for, so the amount of time we keep
your personal information for may vary.
In
all cases, our need to use your personal information will be reassessed on a
regular basis, and information which is no longer required for any purposes
will be disposed of.
8. Automated
decision-making
In some instances, our use of your
personal information may result in automated decisions being taken (including
profiling) that legally affect you or similarly significantly affect you (for
example, whether you are accepted for a loan).
By “automated decisions” we mean
decisions made solely by automated means (for example, software algorithms)
without any human review. By “profiling” we mean automated processing of
personal data to evaluate certain things about you. For example:
●
we use automated decisions and profiling
to assess your suitability for our products and/or services (including
affordability), the interest rate we should offer you, if you are eligible for
a product with different contractual terms i.e. loan amount and/or term and to
predict the likelihood of you making repayments; or
●
if our processing
reveals your behaviour to be inconsistent with your previous submissions, or
you appear to have deliberately hidden your true identity, or you appear on an
official sanctions list, our systems may automatically determine that you pose
a fraud or money laundering risk.
The personal information that we may use
as part of any automated decisions (including profiling) includes the
information that you (or third parties) provide to us, as described above.
Where sensitive personal information is relevant to the profiling, such as health data, your
sensitive personal information may also be used in the models.
Automated decision-making is used so
that we can determine efficiently and accurately whether to offer you the
products and/or services you apply for (and therefore whether we can enter into
a contract with you) or offer suitable alternatives (if eligible) and so that
we can perform our obligations under our contract as a responsible lender.
We have implemented measures to
safeguard the rights and interests of individuals whose personal information is
subject to automated decision-making. When we make an automated decision about
you, you have the right to contest the decision, object to profiling, to
express your point of view, and to require a human review of the decision. You
can exercise this right by emailing us at
hello@salaryfinance.com
.
If you object to automated decision-making or profiling of your personal data,
this may affect our ability to provide you with the products and/or services
that you request.
9. How
we process your data for the purpose of fraud prevention and detection
Summary:
The
personal information we have collected from you will be shared with fraud
prevention agencies who will use it to prevent fraud and money-laundering and
to verify your identity.
If
fraud is detected, you could be refused certain services, finance, or employment.
Further details:
General
Before
we provide services, goods or financing to you, we undertake checks for the
purposes of preventing fraud and money laundering, and to verify your identity.
These checks require us to process personal data about you.
The
personal data you have provided, we have collected from you, or we have
received from third parties will be used to prevent fraud and money laundering,
and to verify your identity.
Details
of the personal information that will be processed include, for example: name,
address, date of birth, contact details, financial information, employment
details, device identifiers including IP address and vehicle details.
We
and fraud prevention agencies may also enable law enforcement agencies to
access and use your personal data to detect, investigate and prevent crime.
We
process your personal data on the basis that we have a legitimate interest in
preventing fraud and money laundering, and to verify identity, in order to
protect our business and to comply with laws that apply to us. Such processing
is also a contractual requirement of the services or financing you have
requested.
Fraud
prevention agencies can hold your personal data for different periods of time,
and if you are considered to pose a fraud or money laundering risk, your data
can be held for up to six years.
Automated
decisions
As
part of the processing of your personal data, decisions may be made by
automated means. This means we may automatically decide that you pose a fraud
or money laundering risk if our processing reveals your behaviour to be
consistent with money laundering or known fraudulent conduct, or is
inconsistent with your previous submissions, or you appear to have deliberately
hidden your true identity. You have rights in relation to automated decision
making: if you want to know more please contact us using the details above.
Consequences
of processing
If
we, or a fraud prevention agency, determine that you pose a fraud or money
laundering risk, we may refuse to provide the services or financing you have
requested, or to employ you, or we may stop providing existing services to you.
A
record of any fraud or money laundering risk will be retained by the fraud
prevention agencies, and may result in others refusing to provide services,
financing or employment to you. If you have any questions about this, please
contact us on at
hello@salaryfinance.com
.
Data
transfers
Whenever
fraud prevention agencies transfer your personal data outside of the European
Economic Area, they impose contractual obligations on the recipients of that
data to protect your personal data to the standard required in the European
Economic Area. They may also require the recipient to subscribe to ‘international
frameworks’ intended to enable secure data sharing.
Your
rights
Your
personal data is protected by legal rights, which include your rights to object
to our processing of your personal data; request that your personal data is
erased or corrected; request access to your personal data.
For
more information or to exercise your data protection rights, please see below.
You
also have a right to complain to the Information Commissioner’s Office which
regulates the processing of personal data. Further details are set out below.
10. Your
rights in respect of the processing
It is important that you understand your
rights in relation to your personal information and how you can contact us if
you have any concerns or queries.
Where you have given us consent to
process your personal information, you have the right to withdraw that consent
at any time by contacting us at
hello@salaryfinance.com
.
This will not affect the lawfulness of processing based on your consent carried
out prior to you withdrawing your consent.
You have a right to request access to or
rectification of your personal information (including any information we have
used to create any profile) that we hold about you, free of charge. You also
have the right to erase your personal information, to restrict or stop
processing or delete it. We have up to 30 days to respond to your request.
Whilst we provide the information requested without a fee, further copies requested
by you may incur a charge to cover our administrative costs. It’s worth noting
that in some cases if you do ask us to correct, delete or stop processing it,
we won’t always be required to do so. In such instances, we will explain why.
To request a copy of the personal information we hold about you, please submit
your request via email to
hello@salaryfinance.com
and provide your name, postal address and telephone number and any other proof
of identification that we may request. If you are contacting us on behalf of
someone else, you must provide signed authority from the individual whose data
is required.
Where requests are made this will be in
accordance with legal, regulatory, accounting requirements and our retention
policy as stated below.
In certain circumstances you can request
that we provide the information we hold about you either to you or a third
party in a commonly used and machine readable format. This includes but is not
limited to CSV documents.
11. Security
The security of your Personal Information is very important to Salary Finance.
We use physical, electronic, and administrative controls that are designed to
protect your Personal Information from loss, misuse and unauthorised access,
disclosure, alteration and destruction.
We have several layers of security measures in place to protect your information, including:
●
Enterprise-level security infrastructure, including physical security measures,
to guard against unauthorised access to systems;
●
Up-to-date, automated, and centralised anti-virus software to protect against viruses damaging data and infrastructure;
●
Regular reviews of our information collection, storage and processing practices, including backups, encryption, and retention; and
●
On-going governance and auditing in line with industry best practices and international certification standards.
12. How to make a complaint about the use of your data
We endeavour to deliver the best levels
of customers service however if your think we are falling short please contact
our data protection officer at
hello@salaryfinance.com
.
If you’re unsatisfied with any aspect of
how we handle your personal information you have the right to contact the
Information Commissioner’s Office, the supervisory authority.
1.
Going to their website at https://ico.org.uk/.
2.
Phone on 0303 123 1113.
3.
Post to Information Commissioner’s
Office, Wycliffe House, Water Lane, Wilmslow, K9 5AF.
13. Changes
to this Privacy Policy
We
can update this Privacy Policy at any time and will place any updates on our
website. This privacy policy was updated on 25 September 2019.