Privacy Policy

1. WHO WE ARE 

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


2. DATA PROTECTION PRINCIPLES  

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:

  1. processed fairly, lawfully and in a transparent manner;
  1. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
  1. adequate, relevant and limited to what is necessary;
  1. accurate and, where necessary, kept up to date;
  1. not kept for longer than necessary; and
  1. processed securely, maintaining integrity and confidentiality.


3. SOME BASIC DEFINITIONS WE USE IN THIS POLICY

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. 


4. THE KIND OF PERSONAL DATA WE HOLD ABOUT YOU  

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:

  • Personal contact details such as name, title, addresses and personal email addresses
  • Job title and place of work
  • Demographic information such as your postcode
  • Date of birth
  • Gender
  • Relationship status and dependants
  • Bank account or debit/credit card details and banking provider name
  • Details you may provide to us about your income and expenditure, including any historic debts
  • Information about your use of our information and communications systems
  • Any information you make available, or transmit to us, via social media accounts
  • Details of transactions you carry out through our website or app or by other means, the fulfilment of your instructions and any subsequent communications with you about any of these.
  • Details of your visits to our website or app including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own administrative purposes or otherwise and the resources that you access.
  • We may record telephone conversations for training and security purposes. You will be notified if recording is taking place at the commencement of any call.

We do not collect, store or use sensitive personal data.


5. HOW IS YOUR PERSONAL DATA COLLECTED?  

In the course of our business, we may collect personal data directly from an individual:

  • when you provide information in relation to services we might provide to you;
  • when you submit an enquiry about our services;
  • when you sign up to our mailing list; and
  • when you provide personal data directly to members of our team.

We may also collect personal data about individuals from other sources such as:

  • Credit agencies, who will grant us access to your credit information when you request a search via our site or app.  Despite our efforts, we cannot guarantee that this data is completely accurate all the time. 
  • Third party providers whose offers, products or services are advertised via our website or app, who will provide details to us of any transaction you enter into with them after our promotion of their services
  • Open banking providers, who we use to verify a user’s identity and pull transaction details
  • Marketing agencies or referrers who may provide us with information

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.


6. HOW WE WILL USE PERSONAL DATA

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.

  • To provide you with offers, products and services as a result of a soft search credit check and processing the details provided to us. We may repeat this process and refresh your results periodically in order to present current offers, products and services which in either case may involve sharing your data with our partners, including credit agencies and lenders (name, contact details, dates of birth, title, address, employment status, relationship status, no. of dependents any income, expenditure and banking information provided and other data you may input as part of any such check).

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

  • To share your details with our partners whose offers and services are included on our site or app, with a view to them providing you with an online quote for the offer/service requested by you (name, contact details, dates of birth, any income, expenditure and banking information provided and other data you may input as part of any such check). 

When our partners use your personal data to provide an offer they will act as data controllers of your personal data and you should ensure you are comfortable with any third party’s privacy policy.

  • To analyse data in order to estimate impacts of changes to your credit history or provide you with nudges and alerts (contact details, data provided via our site or app for previous credit checks or eligibility scores and any information relating to personalisation preferences).
  • To ensure that content from our website or app is presented in the most effective manner for you and for your device (online identifiers, location data and other technical information).
  • To provide you with information, products or services that we feel may interest you, (where you have consented to be contacted for such purposes to the extent consent is required by law) (contact details and any information relating to personalisation preferences).  Please note that this may be generated automatically but no decisions about you that may have a significant effect are based on automated information.
  • To allow you to participate in interactive features of our service, including setting up an account, when you choose to do so (online identifiers, device identification data, location data and other technical information).
  • To notify you about changes to our service (contact details).
  • To maintain a basic amount of information about you and your transaction history, in order to provide you with a service tailored to your preferences (contact details, payment history and any information relating to personalisation status).

Basis of processing: Where we need to comply with a legal or regulatory obligation.

  • To comply with anti-money laundering obligations (name, date of birth, current and recent addresses (if provided), bank account and transaction history)
  • To retain basic transaction details (where you enter into an agreement for anything promoted via our website or app) for the purpose of tax reporting or compliance with FCA regulation (contact details and transaction history).

Basis of processing: Where you have consented to the processing.

  • To allow us to pull your credit file in order to gain relevant background history, which requires sharing your data with open banking providers for verification purposes (name, date of birth, current and recent addresses (if provided), bank account and transaction history).

When Equifax or any other open banking provider uses your personal data to verify information they will act as data controllers of your personal data and you should ensure you are comfortable with their own privacy policy.

  • To use non-essential cookies on our website or app (see “Cookies” section below for further information) (online identifiers, location data and other technical information).  You have the right to withdraw consent to such use at any time by contacting us but please note that some or all parts of our website or app may no longer be accessible to you.
  • To send you direct marketing communications via email, text message, post or telephone call (contact details).  You have the right to withdraw consent to any such use at any time by contacting us.
  • To provide you with advertising on our website or app that we feel is suited to your interests, based on information you have provided to us (transaction history, device details, any information about browsing history and your journey to and within our website)

Other issues about how we use personal data:

  1. Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.  Please contact us at help@bettercents.io if you need details about the specific legal basis we are relying on to process your personal data – contact details are below.  
  1. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.  Please contact us if you would like further details of any additional purposes of processing.  If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.
  1. Unless you provide us with details related to dependants who are under the age of 18, we do not knowingly collect or otherwise process personal data relating to children or youngsters.  You should not use our service if you are under the age of 18.  We reserve the right to cancel the account of any user found to be under age and securely delete any data relating to them.
  1. Please note that we may process your personal data without your knowledge or consent where required or permitted by law.
  1. We may collect, use and share aggregated data such as statistical or demographic data for any purpose.  Aggregated data may be derived from your personal data but is not considered “personal data” in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your website or app usage data to calculate the percentage of users accessing a specific website or app feature.  However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
  1. If you provide us with any personal data relating to relatives, partners or other individuals such as joint account owners it is your duty to make such persons aware that their personal data may be shared with us and to provide them with appropriate information about how their personal data may be processed by us. By providing those details, you are confirming that those persons have read this policy and agree to our use of their data.


7. DIRECT MARKETING 

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:

  • sending promotional emails about new products, special offers or other information which we think you may find useful or interesting using the email address which you have provided; 
  • contacting you for market research purposes (by email, text message, post or telephone call).

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.


8. CONSENT

In this policy, where we have referred to needing your consent for any processing, we will make sure that the consent:

  • is specific consent for one or more specified purposes; and
  • is given by a clear affirmative act establishing a freely given, specific, informed and unambiguous indication of your agreement to the relevant processing of personal data.


9. AUTOMATED DECISION-MAKING  

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.


10. DATA SHARING  

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:

  • the country to which the personal data is transferred ensures an adequate level of protection for that individual’s rights and freedoms; 
  • the transfer is covered by one of the derogations set out in the GDPR, including the performance of a contract between us and that individual, or to protect the vital interests of individuals;
  • the transfer is legally required on important public interest grounds or for the establishment, exercise or defence of legal claims; or
  • the transfer is authorised by the relevant data protection authority where we have checked adequate safeguards exist with respect to the protection of the individual’s privacy, their fundamental rights and freedoms, and the exercise of their rights.

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: 

  • We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK government.
  • Where we use service providers, we may use specific contracts approved by the UK government which give personal data the same protection it has in the UK. 

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:

  1. We use Monevo to provide our loan product offers. (Monevo Limited is an Appointed Representative of Quint Group Limited, and is entered on the Financial Services Register under reference number: 723672. Quint Group Limited is authorised and regulated by the Financial Conduct Authority and is entered on the Financial Services Register under reference number: 669450. Monevo Limited is registered in England and Wales (Company number 06511345). Registered Office: Glasshouse, Alderley Park, Nether Alderley, England, SK10 4ZE
  2. We use Habito to provide you with mortgage product offers. (Hey Habito Ltd. is registered in England and Wales (09384953) with address C/O Throgmorton, 4th Floor, Reading Bridge House, George St, Reading, Berkshire RG1 8LS, is authorised and regulated by the Financial Conduct Authority and is on the Financial Services Register under reference number: 714187)
  3. We use Equifax to access your credit information. We cannot guarantee that this data is completely accurate all the time. When we make requests from Equifax 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. (Equifax Limited is registered in England with Registered No. 2425920. Registered Office: 1 Angel Court, London, EC2R 7HJ. Equifax Limited is authorised and regulated by the Financial Conduct Authority and is on the Financial Services Register under reference number: 739000)
  4. We also use Equifax, an open banking provider, to verify information you may choose to disclose to us
  5. We use Zoopla to determine the value of your home in order to inform our algorithms and to send this information to our above partners to understand your eligibility for any given product (Zoopla Limited is registered in England with with Registered No. 06074771. Registered Office: The Cooperage, 5 Copper Row, London SE1 2LH. Zoopla Limited is authorised and regulated by the Financial Conduct Authority and is on the Financial Services Register under reference number: 754970)

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:

  • Amazon Web Services, for hosting 
  • Open banking providers such as Equifax (who will also collect data from you directly and act as a controller in their own right)

11. DATA SECURITY  

We will always take appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing (including taking reasonable steps to ensure the reliability of employees who have access to personal data). Our employees may only process personal data in accordance with this privacy policy, and any employee who breaches this privacy policy may be subject to disciplinary action, up to and including dismissal.

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.


12. DATA RETENTION  

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.


13. YOUR RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data, as summarised below. 

You have the right to:

  1. Request access to your personal data (commonly known as a “data subject access request”).  This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  1. Request correction of the personal data that we hold about you.  This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  1. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.  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.  Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  1. Object to processing of your personal data where we are relying on a legitimate interest (of our own or 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 to process your information which override your rights and freedoms.
  1. Request restriction of processing of your personal data.  This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  1. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  1. Withdraw consent at any time where we are relying on consent to process your personal data.  However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.  If you withdraw your consent, we may not be able to provide certain products or services to you.  We will advise you if this is the case at the time you withdraw your consent.

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.

14. COOKIES

Our website or app uses cookies to distinguish you from other users of our website.  This helps us to provide you with a good experience when you browse our website or app and also allows us to improve our website or app.

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: 

  • Strictly necessary cookies. These are cookies that are required for the operation of our website or app. They include, for example, cookies that enable you to log into secure areas of our website or app. 
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website or app when they are using it. This helps us to improve the way our website or app works, for example, by ensuring that users are finding what they are looking for easily. 
  • Functionality cookies. These are used to recognise you when you return to our website or app. This enables us to personalise our content for you and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our website or app, the pages you have visited and the links you have followed.  We will use this information to make our website or app and any advertising displayed on it more relevant to your interests.  We may also share this information with third parties for this purpose.

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.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control.  These cookies are likely to be analytical/performance cookies or targeting cookies.

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.

15. CHANGES TO THIS POLICY 

We reserve the right to change this policy at any time. Where appropriate, we will notify individuals of those changes by post or email.  Each time you enter or use our website or app, you agree that the privacy policy current at that time shall apply to all information we hold about you.

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.


16. CONTACT

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to help@bettercents.io.

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.


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