Privacy Policy

 

BACKGROUND:

Perfect Data Solutions Limited Trading as LendingMetrics understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our consumer, client, and employee data and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

 

  1. Information About Us
    Perfect Data Solutions Limited Trading as LendingMetrics.

    A limited company registered in England under company number 7407815. Registered office: Lancaster Court, 8 Barnes Wallace Road, Fareham PO15 5TU. VAT number: 120152968.

    Data Protection Officer: Neil Williams.
    • Email address: neilw@lendingmetrics.com.
    • Telephone number: 01845 544 2823.
    • Postal Address: Lancaster Court, 8 Barnes Wallace Road, Fareham PO15 5TU.

    We are authorised and regulated by the FCA - Financial Conduct Authority (No. 730062).

  2. What does this notice cover?
    This Privacy Notice explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

  3. What is Personal Data?
    Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

    Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

    The personal data that we use is set out in Part 6, below.

  4. For what purpose is my Personal Data used?
    If you are a consumer your Personal Data may be used in any of the following ways:

    LMX
    We procure searches from the main credit reference agencies. We use this data to provide credit search services to our clients. Our clients are predominantly lenders who use our data in order to make lending decisions to consumers by obtaining, amongst other things, credit reference reports, anti-money laundering checks, fraud detection reports and identity verification reports from us. We call this service LMX.

    True Time 
    We also maintain our own database which records and provides a history of consumer credit activity reported to us by our clients in order that future lending decisions can be made responsibly and over indebtedness avoided. We call this service True Time.

    Bank Vision and Open Bank Vision
    We provide software platforms for our client’s to make lending decisions. This can involve data capture of a consumer’s recent bank account activity. These services  are called Bank Vision and Open Bank Vision.

  5. What are my rights?
    Under the GDPR, you have the following rights, which we will always work to uphold:
    1. The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 12.
    2. The right to access the personal data we hold about you. Part 11 will tell you how to do
    3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 12 to find out
    4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 12 to find out
    5. The right to restrict (i.e. prevent) the processing of your personal
    6. The right to object to us using your personal data for a particular purpose or purposes.
    7. The right to data portability. This means that you can ask us for a copy of your personal data held by us to re-use with another service or business in many cases.
    8. Rights relating to automated decision-making and profiling. Part 7 explains more about how we use your personal data, including automated decision-making

    For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 12.

    Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

    If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

  6. What Personal Data do you collect?
    We may collect some or all of the following personal data (this may vary according to your relationship with us:
    • Name;
    • Date of birth;
    • Address;
    • Email address;
    • Telephone number;
    • Business name;
    • Job title;
    • Profession;
    • Payment information;
    • Employment Information;
    • National Insurance Number;
    • IP Address;
    • Bank Account and Transition Information;
    • Credit agreements (past and present);
    • Credit payment;

    We may also collect personal information on you from places such as business directories, public registers and other commercially or publicly available sources e.g. to check or improve the information we hold (like your address) and/or to verify various details.

  7. How do you use my Personal Data?
    Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract to which you are a party or prior to you becoming a party, because you have consented to our use of your personal data, when it is our legal duty or because it is in our legitimate business interests to use it or that of a legitimate third party such as one of our  clients. Your personal data may be used for one of the following purposes:
    • Sourcing, providing and managing a credit account.
    • Supplying our products and services to you or our clients in order that they make lending decisions. Your personal details are required in order for us to enter into a contract with you or for any of our client’s to do so.
    • Personalising and tailoring our products and services for you.
    • Communicating with you. This may include responding to emails or calls from you.
    • Supplying you with information by email and post that you have opted-in to (you may unsubscribe or opt-out at any time by Informing us that you would no longer like to receive information from us, This can be done in an email to info@lendingmetrics.com or in writing to Customer Service LendingMetrics, Lancaster Court, 8 Barnes Wallace Road, Fareham, PO15 5TU ).

    With your permission and/or where we have a legitimate business interest or as otherwise permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and telephone, text message and post with information, news, and offers on our products and services. You will  not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

    We do not make any automated decisions based upon your Personal Data. Some of our clients may utilise a software platform we provide called Automatic Decisioning Platform (ADS) to make automated lending decisions in respect of credit applications received from consumers.

  8. How long will you keep my Personal Data?
    We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

    Consumer Data, where Lending Metrics is the Data Controller:
    • LMX
      • LMX Searches sourced from Equifax (Credit, AML, Bank Verifier and Income Verifier) outcomes will be securely retained for up to 12 months before being purged.
      • Monthly Reporting files are supplied from the Client and passed to Equifax. Lending Metrics will securely retain each monthly reporting file for up to 3 months before being purged.
    • Bank Vision
      • Searches that do not result in Bank Statement data will be securely retained for up to 6 months before being purged.
      • Searches that do result in Bank Statement data will be securely retained for up to 24 months before being purged.
    • True Time
      • Reported Leads will be securely retained for up to 45 days before being purged.
      • Reported Applications will be securely retained for up to 120 days before being purged.
      • Reported Loans will be securely retained whilst the Loan remains open or up to 6 years after repayment before being purged.
      • Searches outcomes will be securely retained for up to 12 months before being purged.
    • Open Bank Vision
      • Searches that do not result in Bank Statement data will be securely retained for up to 6 months before being purged.
      • Searches that do result in Bank Statement data will be securely retained for up to 24 months before being purged.

    Consumer Data, where Lending Metrics acts as a Data Processor on behalf of our Client who are the Data Controller:

    • Auto Decisioning Platform (ADP)
      • Submitted transactions will be securely retained based on the Clients’ own stated Data Retention Policy, typically between 3 - 12
      • As a Data Processor, the Client should be contacted directly for clarification.
    • LMX
      • From time to time a Client may provide a batch file containing bulk Consumer data used to run a retrospective analysis. In this process Lending Metrics act as a Data Processor, therefore will securely retain each file for up to 6 months before being purged.
    • Client/ Prospect
      • Existing Client, Lending Metrics will keep the data for the entirety of the contract. Should the partnership end then Lending Metrics will hold the data for up to 2 years, this is to ensure that we are able to inform historical clients of any changes that may be of interest to them or their business needs.
    • Employee and potential Employee’s
      • Lending Metrics will collect data through CV’s and applications during any interview process. Any applications that are unsuccessful will be retained by the company for a 12-month period. All employee data will be retained for the entirety of their employment. After employment the company will retain elements of the data in order for the company to conduct references for new employers, this data will be kept for up to 6 years.

  9. How and where do you store or transfer my Personal Data?
    We will only store your personal data in the UK. This means that it will be fully protected under the GDPR.

  10. Do you share my Personal Data?
    Personal data is shared to our clients as part of the commercial services we provide.

    Our clients must demonstrate a legitimate business reason for using our services and enter into agreement with us to ensure that the they will protect the integrity and confidentiality of any personal data they receive from us and maintain adequate security in order that any breach of data is minimised.

    Generally, a consumer will be notified of credit searches being undertaken on their behalf.

    Our clients are also required to inform of us of any material change to any personal data within a reasonable time.

    Any inaccuracies in personal data should be reported to us. As we rely  upon receiving reports of personal data and upon public registers we cannot be held responsible for the accuracy of your Personal Data. We shall investigate any inaccuracies notified to us and if these cannot be resolved we shall notify you in order that you can seek to resolve with the reporting entity directly.

    In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, to help prevent fraud, tax evasion or money laundering or upon the instructions of a government authority.

  11. How can I access my Personal Data?
    If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

    All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 12. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

    There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

    We will respond to your subject access request within 28 Business days and, in any case, not more than one month of receiving it. Normally, we aim to provide a  complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

  12. How do I contact you?
    To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Customer Services):
    • Email address: info@lendingmetrics.com
    • Telephone number: 01845 544 2823.
    • Postal Address: LendingMetrics, Lancaster Court, 8 Barnes Wallace Road, Fareham PO15 5TU.

  13. Is my Personal Data secure?
    We take information and system security very seriously and we strive to comply with our obligations at all times. Any Personal Data which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.

    Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our security controls are aligned to good practice standards providing a controlled environment that effectively manages risks to the confidentiality, integrity and availability of your information.

  14. Can I request a copy of my credit report from you?
    You have the right to request a credit reference report from us for £2.00. You can request this from us by contacting us using the contact details shown at paragraph 12 above.

  15. Changes to this Privacy Notice
    We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

    Any changes will be made available through our website, www.lendingmetrics.com and will be deemed to be accepted by you upon your first visit following the publication of any update. You are reminded to check the relevant page of our website for updates.

  16. Our Website
    Our website can be found at www.lendingmetrics.com. This Privacy Notice applies to the use of our website. Our website contains links to other websites. However, we have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

  17. Our Use of Cookies
    A cookie is a small text file placed on your computer when you access our website. We use cookies to improve your experience of using our website and to improve our range of services. Our cookies are carefully selected to ensure that your privacy is protected and respected at all times.

    Before our website places cookies on your computer, you will be presented with a message bar requesting your consent to set those cookies. By giving your consent to the placing of cookies, you are enabling us to provide a better experience and service to you. You may, if you wish, deny consent to the placing of cookies; however certain features of the website may not function fully or as intended.

    Our website may place the following cookies:

    Type of Cookie

    Purpose

    Strictly necessary cookies

    These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website or make use of e-payment services.

    Analytical/performance cookies

    They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

    3rd party cookies

    These are cookies placed on your computer by approved third party companies. For example, when an embedded video from Vimeo is interacted with.

    You can choose to enable or disable cookies in your internet browser. By default, most internet browsers accept cookies but this can be changed. For further details, please consult the help menu in your internet browser.

    You can choose to delete cookies at any time; however you may lose any information that enables you to access the website more quickly and efficiently including, but not limited to, personalisation settings.

    It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

  18. What happens if your business changes hands?
    We may, from time to time, expand or reduce our business and this may involve the sale and / or the transfer of control of all or part of our business. Any personal data that you have provided will, where it is relevant to any part of our business that has been transferred, be transferred along with that part and then new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use that data only for the same purposes for which it was originally collected by us.

    In the event that any of your data is to be transferred in such a manner, you will not be contacted in advanced and informed of the changes.

  19. General
    You may not transfer any of your rights under this Privacy Notice to any other person. We may transfer our rights under this Privacy Notice where we reasonably believe your rights will not be affected.

    If any court or competent authority finds that any provision of this Privacy Notice (or part of any provision) is invalid, illegal or unenforceable, that provision or part- provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Notice will not be affected.

    Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

    This Privacy Notice is governed by and interpreted according to English law. Any disputes arising under this Privacy Policy are subject to the exclusive jurisdiction of the English courts.