Advancis Limited trading as 'GuarantorLoans4Me' (referred to herein as GuarantorLoans4Me and by the words 'us' 'we' and 'our') is a lender which provides consumers with guarantor loans regulated by the Consumer Credit Act 1974. We are a private limited company registered in England and Wales under company number 08089541 and have our registered office address at Alexandra Court, Carrs Road, Cheadle, Cheshire, SK8 2JY.
Please read the following carefully to understand our views and practices regarding your personal data.
Personal data is any information from which you may be identified, directly or indirectly. We may process the following personal data about you:
Information that you provide, for example by filling in forms on the Website and when progressing any application for a loan (including via our online portal) or when you propose to act as a guarantor including:
- Basic personal information such as your name, date of birth, gender and the relationship between borrower and guarantor.
- Your contact details such as postal address, email address and phone number.
- Verification information such as past addresses, debit card details and proof of income and expenditure.
- Details of any loan applied for such as the amount, preferred repayment period, and bank details for making repayments.
- Information we need to assess the affordability of the loan such as your employment details and your monthly income.
- Identifiers assigned to your computer or other devices, including your Internet Protocol (IP) address and other information about your visits to the Website.
- Any other personal data that you choose to provide on the Website or in your communications with us. Please note, call recordings of conversations may be retained for monitoring and training purposes, except where bank card details are provided when the call recording will be paused.
Information that we may obtain from third parties such as:
- If you own any property, we may carry out a search with the land registry – We do not place any charge on the property as security for providing the loan. Performing the search helps us verify you and, in some cases, means we can lend higher amounts.
- A credit check will be carried out by TransUnion to view your financial commitments. For further details, please refer to the Credit Reference Agencies section under "4. Sharing your personal data" below. If you advise of any other financial commitments not shown on the credit file, details will be retained.
- Buddy Loans may also carry out a soft credit search if payments are missed or if we are unable to contact you.
- Details of your health or medical history if you have provided explicit consent for Buddy Loans to note these on your records.
- We may obtain information about complaints from the Financial Ombudsman Service if you escalate a complaint.
- If you are proposed to act as a guarantor, we may obtain your details (e.g. name, address, phone number) from the relevant borrower. We will process guarantor personal data in accordance with this Policy. If you are providing us with information about a proposed guarantor, you must first direct the relevant individual to this Policy before providing us with any personal data.
Information that may be generated during the course of your relationship with us, for example:
- Details of repayments that you have made or missed;
- Account reference details on our system; and
We may process your personal information for the purposes of:
- administering your application and agreement with us either as borrower or guarantor (as is necessary for performance of a contract between you and us or to take steps to enter into one, and as is necessary for our legitimate interests);
- carrying out anti-fraud and anti-money laundering checks and verifying your identity and ensure your suitability and affordability for a loan or to act as a guarantor (as is necessary for compliance with our legal obligations);
- assessing financial risks, including by carrying out credit reference checks on both borrowers and guarantors (as is necessary for the performance of a contract between you and us and as is necessary for our legitimate interests);
- using your payment details to process payments relating to your repayments, and refunds, including via a Continuous Payment Authority (CPA) if you have agreed to this (as is necessary for the performance of a contract between you and us);
- communicating with you about your application or agreement, including responding to your enquiries (as is necessary for the performance of a contract between you and us and as is necessary for our legitimate interests);
- administering debt recoveries, where you owe us money under a contract or otherwise (as is necessary for the performance of a contract between you and us and as is necessary for our legitimate interests);
- undertaking statistical analysis, including analysing your use of our Website. This allows us to develop new, or improve existing, products and services (as is necessary for our legitimate interests); and
- fulfilling our obligations owed to a relevant regulator, tax authority or revenue service (as is necessary for compliance with our legal obligations).
Our "legitimate interests" as referred to above include our legitimate business purposes and commercial interests in operating our business in a customer-focused, efficient, and sustainable manner, in accordance with all applicable legal and regulatory requirements. Your personal data may be used for the purposes of automated decision making. Upon making a loan application, we obtain your credit file from TransUnion via a soft search and use this information to assess your creditworthiness and whether you can afford to take the product.
Special category personal data
We may occasionally process personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships, genetic or biometric data, data concerning health, or data concerning your sex life or sexual orientation. For example, you may inform us about health conditions that impact your ability to repay, or if you are acting as a borrower and your proposed guarantor is stated to be your spouse then this may indicate sexual orientation.
This data is considered 'special category personal data' under the Data Protection Laws. We will generally only process this personal data where you have given your express consent to this, or where it is necessary for the establishment, exercise or defence of legal claims.
Where we process special category personal data on the basis of your express consent, this can be withdrawn at any time. Withdrawing consent will not affect the lawfulness of any processing based on the consent before it was withdrawn. To withdraw consent to the processing of special category personal data, please contact our Data Protection Officer firstname.lastname@example.org or by telephoning 0161 850 4141.
For borrowers, with your guarantor
If you are making a loan application, we may ask you to provide details of individuals who are willing to act as guarantors on your behalf. We will need the guarantor to verify some of the personal information you provide about yourself. We will therefore share this information with the guarantor. We may also share information about you with your guarantor during the course of the loan, for example if the you default on the agreement.
You must have agreed with the guarantor that they will guarantee your obligations should you be offered a loan. All guarantors are subject to the terms of this policy which you must draw to the guarantor's attention before sharing any details with us. This Policy is referenced in the relevant guarantor and Indemnity agreement.
We use GoCardless to process direct debit payments. More information on how GoCardless processes personal data and your data protection rights, including your right to object, is available at https://gocardless.com/legal/privacy/.
Open Banking is a secure way of providing read-only access to your bank or building society account to providers who are registered for this purpose. For more information, visit www.openbanking.org.uk.
In order to enter into and administer your loan agreement you must agree for us to share your personal, contact and loan application details with our registered Open Banking partner, Perfect Data Solutions Limited (PDS) who are also a credit reference agency. During your loan application we shall safely and securely direct you to PDS’s secure portal for the purposes of granting PDS access to your bank or building society account information. As soon as your account information is received it shall be reported back to us in the form of a completed search in order that we may continue to process your loan application.
PDS are registered under the Open Banking Directory as an account information service provider and are also regulated by the Financial Conduct Authority as a payment services firm under number 802599. Any data you submit via the PDS portal will be encrypted and its usage tracked as part of set Open Banking data security standards. Further information about PDS including their registered provider and regulatory status is available from www.lendingmetrics.com.
You will not be required to share your banking password or log in details with either us or PDS. Once you have given your explicit consent to share your bank account information on the PDS portal you will be directed to your own bank or building society’s login page where you will enter in your own login details directly.
With other third parties
We may share your personal information with our associated companies and with certain third parties including:
- Third parties that assist us in preparing or sending 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, or to third parties acting as our agents.
- We reserve the right to sell non-performing accounts. We will inform you if we do this.
- If we are unable to make contact with you, we may employ third party companies to trace your whereabouts and re-engage with us. We may also employ third parties to enforce our rights under any agreement with you.
- If Buddy Loans or its assets are potentially to be acquired by a third party, or if we consider restructuring, personal data held by us about our customers (including borrowers and guarantors) will be one of the transferred assets and may be shared during the potential transaction or restructuring process.
- Anyone to whom we transfer or may transfer our rights and duties under any agreement with you.
- Legal and regulatory bodies, such as the Financial Conduct Authority, the Information Commissioner’s Office, the Financial Ombudsman Service, fraud prevention agencies or when we have a legal obligation to do so.
- Our auditors, solicitors, professional advisors, sub-contractors who have agreed to treat your personal details as confidential.
- If you were introduced to us by a third party, we will provide them details of whether the loan was successful or not. A commission may be paid for the introduction. If you require details of any commission paid, please contact Buddy Loans by using our contact details.
Credit Reference Agencies (CRA)
In order to process your application to borrow from us or act as a guarantor, we will perform credit and identity checks on you with TransUnion (formerly known as Callcredit) who act as a Credit Reference Agency (“CRAs”).
To do this, we will supply your personal information to TransUnion and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. TransUnion will supply to us both public information (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.
We will use this information to, where appropriate:
- Assess your creditworthiness and whether you can afford to take the product.
- Verify the accuracy of the data you have provided to us.
- Prevent criminal activity, fraud, and money laundering.
- Manage your account(s).
- Trace and recover debts.
- Ensure any offers provided to you are appropriate to your circumstances.
We will continue to exchange information about you with TransUnion while you have a relationship with us. We will also inform TransUnion about your settled accounts. If you do not repay in full and on time, TransUnion will record the outstanding debt. This information may be supplied to other organisations by CRAs.
When TransUnion receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.
If you are making a joint application or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. CRAs will 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.
The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods, and your data protection rights with the CRAs are explained in more detail at www.callcredit.co.uk/crain.
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
Where your personal data is transferred outside of the EEA, we will first ensure that there are appropriate safeguards in place to ensure the continued protection of your personal data after it has been transferred (for example by entering into the European Commission's Standard Contractual Clauses with the data importer).
For more information about the specific protections we have in place for any transfers, please contact the Data Protection Officer: email@example.com or by telephoning 0161 850 4141.
We retain your personal data for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).
In accordance with our retention policy, we will retain your personal information for six years from when any loan funds have been released unless the account remains active in which case the data will be retained for 6 years from account closure. For loan applications that did not result in a loan being funded, then your personal information will be deleted two years after loan application was created. Call recordings systems will be retained for six years from when a funded account has been closed and two years if the loan application did not result in funds being released.
We take steps with a view to deleting, destroying, or permanently anonymising your personal data (which means that we are no longer able to identify you from it) when it is no longer necessary for its purpose and we are not required by law to keep it. For further information on Buddy Loans retention policies, please contact the Data Protection Officer: firstname.lastname@example.org or by telephoning 0161 850 4141.
We are aware of the importance of protecting your personal data and we have implemented appropriate organisational and technical security measures to safeguard your privacy rights and freedoms. We store data in encrypted form on computers and control access via secure web pages. We employ firewalls and other security technologies to protect our servers from external attack. We train our employees in the proper handling of personal data and when we use other companies to provide services for us, we require them to protect the confidentiality of personal data they receive.
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 entirely 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.
Your personal data is protected under the Data Protection Laws and you have several rights (explained below) which you can seek to exercise. Please contact our Data Protection Officer email@example.com or by telephoning 0161 850 4141 if you wish to do so, or if you have any queries in relation to your rights.
If you seek to exercise your rights, we will explain to you whether or not the right applies to you; these rights do not apply in all circumstances. Please be aware that if your request is manifestly unfounded or excessive we may refuse to deal with your request or may charge a reasonable fee for dealing with it.
- Right to access: you have the right to access the personal information held about you and to obtain certain prescribed information about how we process it. This is more commonly known as submitting a 'data subject access request'. We may request proof of your identity before sharing such information and in most cases will take no longer than one month from receipt to provide you with all the data we hold about you, although this may be extended in certain circumstances.
- Right to rectify your personal information: if you discover that the information we hold about you is inaccurate or incomplete, you have the right to have this information to be rectified (i.e. corrected).
- Right to be forgotten: you may ask us to delete information we hold about you in certain circumstances, this is often referred to as the 'right to be forgotten'. This right is not absolute and only applies in particular circumstances. It may not therefore be possible for us to delete the information we hold about you, for example, if we have an ongoing relationship or are required to retain information to comply with our legal obligations or to exercise or defend legal claims.
- Right to object to processing: you may object to the processing of your personal information when it is based upon our legitimate interests. You may also object to the processing of your personal information for the purposes of direct marketing and for the purposes of statistical analysis.
- Right to restriction of processing: in some cases, you may have the right to have the processing of your personal information restricted. For example, where you contest the accuracy of your personal information, it may be restricted until the accuracy is verified, or where the processing is unlawful but you object to it being deleted and request that it is restricted instead.
- Right to data portability: you have the right to receive, move, copy, or transfer your personal information to a controller which is also known as 'data portability'. You should note that this right is different from the right of access (see above) and the types of information you can obtain under the two separate rights may be different.
Your Consent- When you submit your application for a loan, we will ask you if you want to receive marketing information from Buddy Loans, about products from Buddy Loans (opportunities to take out new loans, top up loans etc.).
You can decide if you want to receive information and how you want to receive it (email, SMS, telephone, post).
We will not pass your details to other third-party organisations, for the purposes of marketing, without your consent.
If you want to change your marketing preferences, you can update them through your Buddy Loans online portal or make contact with our offices directly.
We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to firstname.lastname@example.org or use the contact details above. We will investigate and respond to any complaints we receive.
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) (the UK data protection regulator). For further information on your rights and how to complain to the ICO, please refer to the ICO website: https://ico.org.uk/ or contact the ICO on 0303 123 1113.
We reserve the right to make changes to this Policy at any time and any significant changes to this Policy will be emailed direct to the primary email address supplied by you; minor changes will be updated directly to the Policy and may not require notification. We advise you regularly review this document to ensure that you are aware of any amendments and to be clear on how this policy may affect you.
This Privacy Notice was last updated on 28 September 2020.