This Policy was created in May 2018 and sets out the rights you have in respect of your personal data. If you have any questions then please contact us on email@example.com.
You have the right to access the personal data we hold (this is commonly known as a “data subject access request” or “DSAR”). This allows you to receive a copy of the personal data we hold about you and to check what we are processing. Please note that we may ask you to specify what you wish to see in order to focus our search, and we may have to verify your identity/authority. The simplest way of accessing your loan documentation and statements is via MyAccount. If you are unable to login to MyAccount please contact our customer service representatives on 0800 7315 444 or 01284 715 444 or email firstname.lastname@example.org.
You have the right to ask us to delete or remove personal data where there is no good reason for us continuing to process it, for example:
You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
Please note that if we are legally obliged to retain your data, we may not be able to comply with your request of erasure. If this is the case, you will be notified at the time of your request.
You have the right to ask us to suspend the processing of your personal data in the following scenarios:
This right only applies to personal data you initially provided consent for us to use or where it was required for the performance of our contract with you, and we used automated means to process it. In such cases we will provide you, or any third party you have chosen to act on your behalf, with your personal data in a structured, commonly used, machine-readable format.
If we are under a legal obligation to process your personal data, for example to conduct an assessment of affordability and creditworthiness, and we use that as part of an automated decisioning process, we are not obliged to provide this data in a machine readable-format.
This right applies where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds. In such cases, these may override your rights and freedoms.
Elevate Credit International Limited (“Elevate”) is committed to safeguarding the privacy of your personal data.
Elevate is registered with the Information Commissioner’s Office (ICO) under registration number Z8907456.
We operate in the UK so if you choose to use our website from outside the UK, you do so at your own risk. This website is not targeted at customers outside the UK.
This Policy was created in May 2018 and provides information in respect of how we and others use your personal data.
Elevate Credit International Limited, is registered in England at 27/28 Eastcastle Street, London, W1W 8DH, under company number 05041905.
If you want ask us about our use of your personal data please contact us at email@example.com
We want to try and make it as clear as possible what it is you are agreeing to when you provide your personal data to us.
When you apply for a loan with us or you provide personal information in respect of someone else’s loan application, you will be asked provide us with information (including name, address, phone number(s), email address, date of birth, income and expenditure information, bank and debit card details). This, and any other information from which you may be identified constitutes personal data.
You may also provide personal data when you speak with our customer services representatives or you update your online account information (My Account).
We may need to update this Policy at any time and without notice and when we do this we will inform you via your online account and/or by email.
When you make an online application we ask you to provide a lot of personal data.
We need the personal data you provide to perform our contract with you, and more specifically for the reasons set out below, including to conduct checks prior to granting a loan, to complete the loan agreement with you, to manage your loan account and to collect payments and/or recover debt. We will also use it to contact you.
We will share your personal data with credit reference agencies (CRAs) and fraud prevention agencies (FPAs) as part of the regulatory requirements placed on us, to conduct creditworthiness and affordability assessments before entering into an agreement with you and to prevent financial crime.
Your personal data is also used for:
These CRA and FPA searches will be recorded. Other credit providers may search these records. Your information may be linked to others living at your address. We may disclose information about how you conduct your account to third parties. We have a legitimate business interest to conduct this type of processing.
We are obligated to provide details back to CRAs and FPAs to inform them of the performance and repayment history of the loan account and suspected or discovered fraud. If you provide false information and/or we suspect fraud we will record this and may report our suspicions to appropriate law enforcement agencies.
We may continue to receive and exchange personal data with CRAs while you have a relationship with us. Please see the Account management section below.
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 and is accessible from each of the three CRAs. By clicking on any of these three links you will be taken to the same document:
We use your personal data to help us manage your loan account with us, this includes personal data you may amend if you update your online account.
Whilst your loan account remains active (whether or not you have an outstanding loan balance), we receive account management data from CRAs and FPAs to help us make decisions as to whether to make additional funds available for you to borrow. We have a legitimate interest in undertaking this process.
We may also share your personal data with third parties to assist in the collection of repayments and recovery of debt and/or if we assign the loan agreement to debt purchasers or if we were to sell our business.
We use your personal data to undertake periodic statistical analysis and/or to ensure the suitability of existing and future products and services. This also helps us to better understand our customers' requirements so we can develop, improve and test products and services. This processing is undertaken as a legitimate interest of the business.
When you correspond with us by phone or e-mail you may also provide personal data. We use this to manage your loan application, your loan account and to respond to any questions or concerns you may have. Phone calls are recorded in the legitimate interests of our business quality and security standards.
Each time you visit our website, certain technical data about you is collected. In some cases this is collected by us and in some cases this is collected by third parties. This includes details about your equipment, browsing actions and patterns.
We may also share your personal data with professional advisers such as our lawyers and insurers to manage risks and legal claims. This is in our legitimate interests.
We may also enter partnerships with third parties to exchange information about you where we think it will give you an opportunity to get a great product or service but we will always inform you about this and ask for your express permission to participate in this.
We may provide suppliers of analytical services or advertising network and search engine providers with aggregate information about our users to help them reach certain demographics. We do not disclose information that identifies you as an individual.
If we offer you the opportunity to invite a friend to try our products using the contacts from a social network service (e.g. your Facebook friends or Gmail contacts then we will only do so with your permission and will only use those contacts for that purpose.
We may share your personal data within our group of companies in order to improve our products and services and because some of our internal support services are shared across the group. This is in our legitimate interests. Our parent company is Elevate Credit Inc. and they are based in the US. We have an inter-company agreement in place which requires our parent company to ensure that the appropriate safeguards are in place.
It is possible we could sell our business to a third party or re-organise our business or become insolvent. In that scenario, our database of customers is one of the biggest parts of that business and so we would need to share it with the third-party buyer and their advisers. This is in the legitimate interests of selling our business.
We will co-operate with all third parties to enforce their intellectual property or other rights. We will also cooperate with law enforcement requests from within or outside your country of residence. This may include disclosing your personal information to government or law enforcement agencies, or private parties, when we have a good faith belief that disclosure is required by law or when we, in our discretion, believe that disclosure is necessary to protect our legal rights, or those of third parties and/or to comply with a judicial proceeding, court order, fraud reduction or legal process served on us. In such cases, we may raise or waive any legal objection or right available to us. These uses of your personal data are in our legitimate interests of protecting our business security. We may also use your personal data and share it with the recipients listed in this policy for the purpose of complying with our legal obligations.
We only send electronic marketing such as email or SMS marketing to people who have provided the relevant consent for us to do so. We will always offer an unsubscribe facility so you can opt out of receiving this marketing when you first make a loan application and in every marketing communication afterwards. We may on occasion send out postal marketing for the purpose of growing our sales which is in our legitimate interests and in this scenario we will rely on you to let us know if you do not want to receive this by opting out of the marketing. To opt-out please email us at firstname.lastname@example.org
You also give us personal data such as contact information when you enter one of our competitions. In these circumstances you are giving us these details to participate. These functions only operate on our website on an opt-in basis and so we rely on your consent to use your personal data in this way.
You also give us your personal data when you participate in discussion boards or other social media functions which we may use from time to time on our website. Operating these discussion boards allows you to share your views with our other customers. This processing of data is in the legitimate interests of the business.
In the majority of cases our lending decisions rely solely on automated decision making and we have a legitimate interest in doing so as our business is solely online and requires decisions to be made consistently and in respect of a number of data points, to ensure we lend responsibly and have undertaken affordability and creditworthiness assessments, in accordance with regulatory requirements.
The personal data that we collect from you will be stored in the UK, however it will also be transferred and stored as follows:
We only store your personal data for as long we need it. Details of our records retention policy is available upon request. To determine the appropriate period we consider the nature of the personal data, its sensitivity, the potential for harm and the regulatory requirements placed upon us. We may delete your personal data on your request – please refer to Your Rights and we may hold a list of the ‘opt out’ requests to record these requests.
You may provide us with following special categories of personal data. This is required for the performance of the contract. Card details are encrypted. Other information is held securely.
All information you provide to us is stored on our servers and we have implemented reasonable and appropriate security measures to protect your personal data including limiting access to key personnel and utilising user names, passwords, encryption and anonymisation where appropriate. Unfortunately, the transmission of information via the internet is not completely secure and we cannot guarantee that data breaches will never occur. Please keep your password safe at all times and log out of inactive sessions. Our website may, from time to time, contain links to and from the websites of our partner networks, 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. Please do not provide us with any other person’s data unless we have specifically prompted you to do so.
For safety purposes, we may require users to verify their accounts (because we want to make sure you are not a robot or a minor). However, with the prevalence of ‘phishing’ you should treat all such emails with caution. We advise that you check our main website by typing in the full address (and not using a ‘cached’ copy of the website on your device) and use the contact details on our website to contact us to verify the request. We also do not recommend that you put email addresses, URLs, phone numbers, full names or addresses, credit card details or other identifying or sensitive information in any online chat function or public profile.
Our products are not aimed at children and neither is our website.
You have various rights under law that assist you with verifying our lawful use of your personal data.
Please refer to our policy for further information here
You may complain to your local supervisory data protection authority about us depending on where you are located. In the UK, please read: https://ico.org.uk/for-the-public/raising-concerns/ for details of how to do this.
Cookies are very small, often encrypted text files that are stored on your computer when you visit certain websites. You can learn more by visiting allaboutcookies.org.
Cookies may either be set by us (first party cookies) or by another party (third party cookies).
These allow us to:
Third party cookies may be used to provide us, our third parties and/or their partners with tracking information which does not identify you personally but which does recognise the device and type of websites and offers which the device is used to visit. In turn these tracking technologies may cause similar products and offers to be displayed on that device by way of banner advertisements and other means when you visit third party websites. This may be used for targeted pay-per-click advertising elsewhere.
The cookies we use can be divided into four categories:
These are essential cookies needed for you to be able to use our website to its full extent. Without some of these
cookies we can’t provide you with the service you want. These cookies cannot be disabled as it may prevent our
website from working properly. These cookies do not gather information about you that can be used for marketing
purposes. Certain cookies allow us to track how our website is performing (i.e. page load times) and how customers
are using the website. They do not track outside of our website and are used by us anonymously.
These cookies collect information about how you have accessed our website and how you use it. This information is
anonymous and used on an aggregated basis to improve how our website works and determine which marketing channels
feed into it. Disabling these cookies will mean we can’t learn how our website is performing and improve the
customer experience for you.
These cookies allow our website to remember you and any choices you’ve made on our website. This can include certain
data inputted/selected by you during your application which may include personal data and log-in details. It will
also recognise if you have come to our website via a promotion and will retain that information so the promotion
remains available to you, whilst applicable. They can also be used to provide services such as watching a video or
leaving comments. Disabling these cookies will mean that we’re unable to carry out the functions above and therefore
your personal data and preferences may have to be reset every time you visit us. It may also mean that some
functionality is not available. These cookies don’t track your browsing activity on third party websites.
These cookies collect information about your browsing habits. They remember what websites you’ve visited and what
products you’ve looked at. This information is then shared with third parties, such as advertisers. This is done in
order to show you more relevant adverts and ensure they’re tailored to your interests. Disabling these cookies will
mean that adverts you see online may be less relevant to you.
The length of time a cookie will stay on your device is dependent on whether they are ‘session’ cookies or ‘persistent’ cookies.
Session cookies: these are set at the start of your visit to our website and only stay on your device until you stop browsing.
Persistent cookies: these are set on your first visit to our website but have an expiry date or time attached to them (usually 540 days). This means that the cookie will stay on your device until either you delete your cookies or the expiry limit is reached.
You may set your preferences when visiting our website to disable certain cookies however this will affect some important functionality of this website, including disrupting your loan application process, and adversely affecting your online account viewing area. When you first arrive on our website you should see the below pop up come up:
You can either accept all our cookies and continue browsing by clicking ‘Continue’ or be taken to our cookie preference function by clicking on ‘More Information’. This function enables you to manage your acceptance of the categories of cookies set out above. Strictly Necessary cookies cannot be turned off as to do so would prevent you from using our website effectively.
You can manage the cookies we use via our Cookie Preference function. This won’t stop cookies from other websites being set. You can block other cookies or remove any already stored on your computer by adjusting your web browser settings. Each web browser has a help section to instruct you on how to do this (normally available via key F1). Here are some links to instructions for the most common browsers: