We are MoneyZen Limited trading as Bettercents (“we”, “us”). Our registered office is at: 20-22 Wenlock Road, London N1 7GU (the “Company” or “we” or “us”). MoneyZen is authorised and regulated by the Financial Conduct Authority as an appointed representative of Promethean Finance Limited (662425), our reference number is 951583.
The Company and personal data: We are committed to lawful, fair and transparent processing of all personal data about our employees, customers, suppliers and other third parties during the course of our business activities. We will always comply with any applicable data protection legislation and we will ensure that collection and use of personal data is carried out in accordance with applicable data protection laws. The main laws governing data protection are the General Data Protection Regulation (Regulation (EU) 2016/679 of 27 April 2016) known as the “GDPR” (as it now applies in English law following Brexit) and the Data Protection Act 2018.
What this policy is: This policy (and any other documents referred to in it, together with any privacy notice displayed on our website or app) sets out the basis on which we will process any personal data about you or individuals generally - whether it’s information we collect from those individuals or that is provided to us from other sources. This policy sets out rules on data protection and the legal conditions that must be satisfied when we obtain, handle, process, transfer or store personal data.
Notification: We comply with current requirements to notify our data processing activities to the Information Commissioner’s Office and are registered under number ZA818286. Please note that, as explained below, we may only be processing your personal data on behalf of another party, who will be the data controller in respect of that information.
Controlling and processing information: We are the controller of all personal data used in our business for our own commercial purposes. Sometimes we may process personal data on behalf of another data controller – and when this is the case, we will do so only in accordance with the instructions of that data controller and otherwise in accordance with the law.
Why you should read this policy: It is important that you read this policy, together with any other documents referred to in it, so that you are aware of how any personal data relating to you will be dealt with by us.
Please remember that any services we provide to you are guidance only and are not specific advice on which you should rely. You should speak to an adviser about your personal circumstances before making any decisions regarding debt or financing
We are accountable for demonstrating compliance with the GDPR’s six principles of processing personal data. These provide that personal data we deal with must be:
Personal data: In this policy, when we use the term “personal data” we mean any information relating to an identified or identifiable human being. (An “identifiable natural person” is one who can be identified, directly or indirectly, for example, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, biometric, mental, economic, cultural or social identity of that person).
Sensitive personal data: In this policy, when we use the term “sensitive personal data” we mean special categories of information which are personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying someone, data concerning health or data concerning someone’s sex life or sexual orientation.
We may collect, record, organise, structure, store, adapt, alter, retrieve, consult, use, disclose by transmission, disseminate or otherwise make available, align or combine, restrict, erase or destroy the following types of personal data about you:
We do not collect, store or use sensitive personal data.
In the course of our business, we may collect personal data directly from an individual:
We may also collect personal data about individuals from other sources such as:
We will only collect personal data to the extent that it is required for the specific purpose notified to individuals about whom we are collecting it - and we will keep it only as long as is necessary.
We will only use personal data when the law allows us to do so and relying on a relevant basis for lawful processing in each instance. We will use your personal data in the following circumstances, relying on the basis of processing indicated:
Basis of processing: Where it is necessary for our legitimate interests (or those of a third party) and we have undertaken an assessment to determine that processing for those interests (listed below) does not outweigh your interests and fundamental rights, considering the nature and impact of the processing and any relevant safeguards we can put in place.
When we make requests from Equifax or other credit agencies for your credit information, this may leave one or more 'soft searches' on your credit file. These soft searches are not visible to lenders or organisations when deciding whether to offer you credit and do not affect your credit score. If you would like to understand how the credit reference agencies use and share data (including the legitimate interests they pursue) please click the following link: www.equifax.co.uk/crain
Basis of processing: Where we need to comply with a legal or regulatory obligation.
Basis of processing: Where you have consented to the processing.
Other issues about how we use personal data:
As indicated above, we may use your personal data to provide you with information about offers, products and services which may be of interest to you and we may contact you about these by email, text message, post or telephone call. This is known as direct marketing.
Examples of direct marketing may include:
We will only process personal data for the above purposes as permitted by law, which usually means with your specific consent. You have the right to withdraw this consent at any time. Information about how to withdraw your consent is set out below.
We may also disclose your information to third parties (including our subsidiaries, our ultimate holding company and its subsidiaries) for the purpose of direct marketing. Again, we will only do this with your explicit consent and you have the right to withdraw this consent at any time. Information about how to withdraw your consent is set out below. Please see “Data Sharing” below for further details.
In this policy, where we have referred to needing your consent for any processing, we will make sure that the consent:
Automated decision-making takes place when an electronic system uses personal data to make a decision relevant to you without human intervention. We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
Transfer of personal data outside of the UK: We may transfer certain personal data that we hold on individuals living in the UK to a country outside the UK, provided that one of the following conditions applies:
Subject to the requirements set out above, the personal data we hold may also be processed by individuals operating outside the UK or EEA who work for us or for one of our suppliers. Those individuals may be engaged in, among other things, the fulfilment of contracts with the relevant individual, the processing of payment details and the provision of support services.
Safeguards: If we use a third party data processor to process personal data on our behalf, we will obtain contractual commitments to safeguard the security of the personal data to ensure that the third party only acts on our instructions when using that personal data and that the third party has in place appropriate technical and organisational security measures to safeguard the personal data. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data outside the UK.
Why we might share your personal data with third parties: We may share personal data we hold in the event that we sell or buy any business or assets, or sell the Company, when we will disclose your personal data to the prospective seller or buyer of such business or assets. We may also disclose personal data we hold to third parties if we are under a duty to disclose or share an individual’s personal data in order to comply with any legal obligation, or in order to enforce or apply any contract with that individual or other agreements; or to protect our rights, property, or safety of our employees, customers or others. This includes exchanging personal data with other companies and organisations for the purposes of fraud protection and credit risk reduction.
In order to provide guidance and suggest offers, products or services, we share personal data with the following partners who use that data to undertake credit checks or confirm eligibility for the offer, product or service you enquire about:
We are an appointed representative of Promethean Finance Limited, which is regulated with the FCA under reference number 662425, and which may also gain access to your data in overseeing our activities.
We may also share data about your use of our site or app with Google Analytics and other third party analytics tools, in order to gain insight into user trends and identify areas for improvement.
We may also share personal data we hold with selected third parties for the purposes set out below. We do not allow our third-party service providers to use your personal data for their own purposes; we only permit them to process your personal data for specified purposes and in accordance with our instructions.
Third party service providers who may process your personal data: When we use the term “third party”, we mean any entity who is not the Company, including third party service providers, contractors and designated agents. The following third party service providers may process personal data for the following purposes:
We have put in place internal procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We will not keep personal data in a form which permits identification of individuals for longer than is necessary for the purpose or purposes for which they were collected. We will take all reasonable steps to destroy, or erase from our systems, all data which is no longer required. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of personal data, the purposes for which we process information and whether we can achieve those purposes through other means, and the applicable legal requirements.
We will only keep personal data for as long as is necessary for the purpose or purposes for which that personal data is processed; and we will let anyone about whom we process data know how long that is or the criteria that go into deciding how long that is. Generally, you can expect us to keep your personal data while you use our website or app, or if you have an active account with us. Where you have applied for or purchased products via our website or app we will need to keep your personal data for longer for accounting purposes - up to six (6) years following the date on which it is provided to us.
We may sometimes anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Our website or app may, from time to time, contain links to and from the websites of 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 or the security of these websites. Please check the relevant policy before you submit any personal data to these websites.
Under certain circumstances, you have rights under data protection laws in relation to your personal data, as summarised below.
You have the right to:
If you wish to exercise any of the rights set out above, please contact us (see below). We aim to respond to all legitimate requests within one month (and if we are only processing the data in question on behalf of another party, the response may actually come from that other party as the relevant data controller). Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive - alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device if you agree. Cookies contain information that is transferred to your computer or device. We use the following cookies:
Cookie: Google Analytics
We may share data about your use of our site or app with Google Analytics in order to gain insight into user trends and identify areas for improvement.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you block cookies you may not be able to access all or parts of our website or app.
Except for essential cookies, all cookies will expire after 12 months.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
You have the right to make a complaint at any time to the Information Commissioner's Office, the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner's Office, so please contact us in the first instance.