Our guide to the use of your personal data by Elevate Credit International Limited and Credit Reference and Fraud Prevention Agencies

1. What is a Credit Reference Agency?

Credit Reference Agencies (CRAs) collect and maintain information on consumers' and businesses' credit behaviour on behalf of organisations in the UK.

2. What is a Fraud Prevention Agency?

Fraud Prevention Agencies (FPAs) collect, maintain and share information on known and suspected fraudulent activity. Some CRAs also act as FPAs.

3. Where do CRAs and FPAs get their information?

From publicly available information:

• the Electoral Register from Local Authorities;
• County Court Judgments from Registry Trust;
• bankruptcy (and other similar) orders from the Insolvency Service;
• fraud information may also come from FPAs;
• credit information comes from information on applications to banks, building societies, credit card companies etc. and also from the conduct of those accounts.

What we do

Please read this section very carefully, it will vary from lender to lender.

• When you apply to us to open an account, this organisation will:
  • Check our own records for information on: -
    • your personal accounts;
    • and, if you have one, your financial associates1 personal accounts;
    • if you are an owner, director or partner in a small business2 we may also check on your business accounts.
  • Search at CRAs for information on: -
    • your personal accounts: -
    • and, if you are making a joint application now or have ever done the following we will check your financial associates' personal accounts as well: -
      • previously made joint applications;
      • have joint account(s);
      • are financially linked3
    • if you are an owner, director or partner in a small business we may also check on your business accounts.
  • Search at FPAs for information on you and any addresses at which you have lived, and on your business (if you have one).
• What we do with the information you supply to us as part of the application:
  • Information that is supplied to us will be sent to the CRAs.
  • If you are making a joint application or tell us that you have a spouse or financial associate, we will: -
    • Search, link and/or record information at CRAs about you both.
    • Link any individual identified as your financial associate, in our own records.
    • Take both your and their information into account in future applications by either or both of you.
    • Continue this linking until the account closes, or is changed to a sole account and one of you notifies us that you are no longer linked.
    So you must be sure that you have their agreement to disclose information about them.
  • If you give us false or inaccurate information and we suspect or identify fraud we will record this and may also pass this information to FPAs and other organisations involved in crime and fraud prevention.
  • Your data may also be used by us to offer you other products, but only if you have given us your permission to do this and you haven’t requested to ‘opt out’ of our marketing campaigns.
• With the information that we obtain we will:
  • Assess this application for credit and/or;
  • Check details on applications for credit and credit related or other facilities.
  • Verify your identity and the identity of your spouse, partner or other directors/partners and/or;
  • Undertake checks for the prevention and detection of crime, fraud and/or money laundering.
  • We may use scoring methods to assess this application and to verify your identity.
  • Manage your personal account with ourselves.
  • Undertake periodic statistical analysis or testing to ensure the accuracy of existing and future products and services.
  • Reserve the right to run any or all of these processes in an automated manner.
• What we do when you have an account:
  • Where you borrow or may borrow from us, we will give details of your personal information, including names and parties to the account and how you manage it/them to CRAs.
  • If you borrow and do not repay in full and on time, we will tell CRAs.
  • We may make periodic searches of our own group records and at CRAs to manage your account with us, including whether to make credit available or to continue or extend existing credit. We may also check at FPAs to prevent or detect fraud.
  • If you have borrowed from us and do not make payments that you owe us, we will trace your whereabouts and recover debts.

What FPAs do

• FPAs work in the following ways with organisations:
  • If false or inaccurate information is provided and fraud is identified, details will be passed to FPAs.
  • Law enforcement agencies may access and use this information.
  • We, and other organisations, may also access and use this information to prevent fraud and money laundering, for example, when:
    • Checking details on application s for credit and credit-related accounts, or other, facilities;
    • Managing credit and credit-related accounts or other facilities;
    • Recovering debt;
    • Checking details on proposals and claims for all types of insurance; and,
    • Checking details of job applicants and employees.
  • We, and other organisations may access and use the information recorded by FPAs from other countries.
• Please contact us at help@sunny.co.uk if you want to receive details of the FPAs we work with

What CRAs do

• When CRAs receive a search from us they will:
  • Place a search 'footprint' on your credit file whether or not this application proceeds. If the search was for a credit application the record of that search (but not the name of the organisation that carried it out) may be seen by other organisations when you apply for credit in the future.
  • Link together the records of you and anyone that you have advised is your financial associate including previous and subsequent names of parties to the account. Links between financial associates will remain on your and their files until such time as you or your partner successfully files for a disassociation4 with the CRAs.
• Supply to us:
  • credit information such as previous applications and the conduct of the accounts in your name and of your associate(s) (if there is a link between you - see 1b above) and/or your business accounts (if you have one);
  • public information such as County Court Judgments (CCJs) and bankruptcies;
  • electoral register information;
  • fraud prevention information.
• When information is supplied by us, to them, on your account(s):
  • CRAs will record the details that are supplied on your personal and/or business account (if you have one) including any previous and subsequent names that have been used by the accountholders and how you/they manage it/them.
  • If you borrow and do not repay in full and on time, CRAs will record the outstanding debt.
  • Records shared with CRAs remain on file for six years after they are closed, whether settled by you or defaulted.
• How your data will NOT be used by CRAs:
  • It will not be used to create a blacklist.
  • It will not be used by the CRA to make a decision.
• How your data WILL be used by CRAs:
  • The information which we and other organisations provide to the CRAs about you, your financial associates and your business (if you have one) may be supplied by CRAs to other organisations and used by them to:
    • Prevent crime, fraud and money laundering by, for example checking details provided on applications for credit and credit related or other facilities.
    • Check the operation of credit and credit-related accounts.
    • Verify your identity if you or your financial associate applies for other facilities.
    • Make decisions on credit and credit related services about you, your partner, other members of your household or your business.
    • Manage your personal, your partner's and/or business (if you have one) credit or credit related account or other facilities.
    • Trace your whereabouts and recover debts that you owe.
    • Undertake statistical analysis and system testing.
• How your data may be used by FPAs:
  • The information which we provide to the FPAs about you, your financial associates and your business (if you have one) may be supplied by FPAs to other organisations and used by them and us to : -
    • Prevent crime, fraud and money laundering by, for example;
      • checking details provided on applications for credit and credit related or other facilities;
      • managing credit and credit related accounts or facilities;
      • cross-checking details provided on proposals and claims for all types of insurance;
      • checking details on applications for jobs or when checked as part of employment.
    • Verify your identity if you or your financial associate applies for other facilities including all types of insurance proposals and claims.
    • Trace your whereabouts and recover debts that you owe.
    • Conduct other checks to prevent or detect fraud.
    • Undertake statistical analysis and system testing.
• Your data may also be used for other purposes for which you give your specific permission or, in very limited circumstances, when required by law or where permitted under the terms of the Data Protection Act 1998.
• Your data may also be used to offer you other products, but only where permitted.

How to find out more

You can contact the CRAs currently operating in the UK; the information they hold may not be the same so it is worth contacting them all. They will charge you a small statutory fee.

• CallCredit, Consumer Services Team, PO Box 491, Leeds, LS3 1WZ or call 0870 0601414
• Equifax PLC, Credit File Advice Centre, PO Box 3001, Bradford, BD1 5US or call 0870 010 0583 or visit www.equifax.co.uk
• Experian, Consumer Help Service, PO Box 8000, Nottingham NG80 7WF or call 0844 4818000 or visit www.experian.co.uk.
• Teletrack UK Limited, 2 St John's Street, Colchester, Essex, CO2 7AA

An explanation of credit scoring

As responsible lenders, we take into account your personal circumstances when approving a credit limit. To help us do this, applications may be assessed using a process called credit scoring.

How does credit scoring work?

Credit scoring takes into account information provided directly by you, any information we may hold about you, and any information we may obtain from other organisations. Where we use information from other organisations, we will tell you which ones these are. We may also use information obtained from Credit Reference Agencies (CRAs).

Credit scoring allocates points for each piece of relevant information and adds these up to produce a score. If your score reaches a certain level, we will generally accept your application and assign you a credit limit. If your score does not reach this level, we may not. Sometimes scores are calculated by CRAs and we may use these in our assessment of your application. The rules for allocating points have been developed based on thorough analysis of a large number of repayment histories collated over many years of providing credit. This statistical analysis enables us to identify characteristics that predict likelihood of future performance. For example, if individuals of a particular age have proved to be more likely to meet payments than those falling within another age group, the points allocated will reflect this.

Credit scoring produces consistent decisions and is designed to ensure all applicants are treated fairly. Additionally, we may have policy rules to determine whether we will lend. These reflect our commercial experience and requirements. Every credit application involves a certain level of risk for the lender, no matter how reliable or responsible an applicant may be. Credit scoring enables us to calculate the level of risk for each applicant based on the information we have obtained. If the level of risk is unacceptable to us, we will not accept the application. This does not mean that any declined applicant is a bad payer; it simply means that based on the information available to us, we are not prepared to take the risk of lending to the applicant. Lenders are not obliged to accept any applications.

Because lenders have different lending policies and scoring systems, applications to them may be assessed differently. This means that one lender may accept your application, but another may not. If your application is declined, this will not be disclosed to the CRAs.

Is credit scoring fair?

We believe that credit scoring is fair and impartial. It does not single out a specific piece of information as the reason for declining an application. We test our credit scoring methods regularly to make sure they continue to be fair and unbiased. Responsible lending is essential for the good of both applicants and lenders. The Financial Conduct Authority regulates credit and considers credit scoring to be an aid to responsible lending.

What happens if your application is declined?

If we are unable to accept your application, we will tell you. We will also tell you the principle reason why we were unable to agree to your request. If you did not pass our credit score, we will tell you this. We will also give you an indication of the type of information that was included in the scoring system. Generally, this information will be grouped into categories such as your ability to repay, your credit history and stability factors, such as how long you have lived at your address. If we have declined your application, you may ask us to reconsider our decision. We will generally ask you to provide us with additional information and tell you what information you will need to give us. If you wish to ask us to reconsider a decision, then please contact us at help@sunny.co.uk

Footnotes

1 A financial associate will be someone with whom you have a personal relationship that creates a joint financial unit in a similar way to a married couple. You will have been living at the same address at the time. It is not intended to include temporary arrangements such as students or rented flat sharers or business relationships.

2 A small business is defined as an organisation which might be sole trader, partnership or a limited company that has three or less partners or directors.

3 CRAs may link together the records of people that are part of a financial unit. They may do this when people are known to be linked, such as being married or have jointly applied for credit or have joint accounts. They may also link people together if they, themselves, state that they are financially linked.

4 Financial associates (see 1. a.) iii) may "break the link" between them if their circumstances change such that they are no longer a financial unit. They should apply for their credit file from a CRA and file for a "disassociation".

Your personal information

Elevate Credit International Limited is committed to respecting and protecting your privacy and ensuring that all of the information we hold about you is correct, relevant and secure. We abide by the Data Protection Act 1998 and are registered as Data Controllers with the Information Commissioner's Office.

Use of your information

By using this website you agree to Elevate Credit International Limited holding and processing your personal and non-personal information for the following purposes to:

• Manage your account
• Make decisions regarding your identity and whether to make further cash available for you to borrow.
• Undertake periodic statistical analysis or testing to ensure the accuracy of existing and future products and services.
• Recover debt.
• Prevent and detect crime.
• Understand our customers' requirements and provide better services.
• Develop, improve and test products and services.

We do not disclose your information to any other person except:

• To credit reference and fraud prevention agencies and other service companies.
• To government entities or regulatory bodies as required by law.
• To sub-contractors who work on our behalf.
• To third parties we contract with in order to improve the products and services that we offer.
• To anyone we have appointed for administration of this agreement.
• To anyone we have appointed for debt collection purposes.
• In the event we sell or otherwise transfer this agreement.

We do not disclose your information to any other person unless:

• We have your permission.
• We are required or permitted to do so by law.

Where we store your personal information

All of your information is stored on our secure servers, and is reviewed on a regular basis to ensure that it remains up-to-date and relevant. We will not retain your personal information for any longer than necessary in line with our Data Protection Act obligations.

Countries within the European Economic Area (EEA) are required to have a similar standard of protection of personal data. We may transfer personal data outside the EEA but will ensure that before we do so, there is adequate protection as required by the relevant Data Protection legislation.

Elevate Credit International Limited is owned by Elevate Credit, Inc., a company based in the USA. From time to time customer data will be securely transmitted to, or our systems accessed by, Elevate Credit, Inc. in order to analyse our data and provide audit services. Elevate Credit, Inc., is certified under the US Safe Harbor Privacy Principles, which ensure that any data transmitted to, or accessed by it, will be used and managed in a way that is as safe, secure and appropriate. To view the full Elevate Credit, Inc., Safe Harbor Privacy Policy click here.

Credit Reference Agencies

We will use the information stored about you to search the files of one or more credit reference agencies for the purposes of credit assessment or account administration.

As part of our application process, we will use and search the records of credit reference or fraud prevention agencies to check your identity and to prevent fraud and money laundering. We will also pass information to such agencies to inform them of the performance and repayment history of the loan account and if fraud is suspected or discovered.

You have the right to receive a copy of your information if you apply to us in writing. A fee (of up to £10.00) will be payable for this service. Please note that we will not provide you with a copy of your credit reference file.

We will, on request, cooperate with any organisation which we are obliged by law so to do. This may involve passing information about you to them.

Using your information for marketing purposes

By submitting your personal information to our website, you are providing consent to use your information for the purposes set out in this document.

Subject to your consent your information might be used to notify you about products and services by phone, email, SMS and in writing from us which may be of interest to you.

You have a right at any time to ask us not to contact you for these purposes. You may send an email to us at unsubscribe@sunny.co.uk if you wish us to stop. If you opt out of such communications, we will honour such choice once we have had a reasonable opportunity to process your request. We reserve the right to take reasonable steps to authenticate your identity with respect to any such request.

We reserve the right to change this Privacy Policy at any time by notifying you of the existence and location of the new or revised privacy policy or by posting the changes online at our website.