Privacy Policy
- Throughout this Privacy Policy “you” means, you, the customer or potential customer.
- We respect your right to privacy and to the protection of your personal information.
- In this Privacy Policy, we seek to describe how we collect, store and use your personal information as clearly as possible.
- This Privacy Policy applies to all personal information processing (i.e. collection, storage, use, disclosure and destruction) carried out by us.
- The Privacy Policy applies from when we collect your personal information until we cease storing your personal information.
If you have any queries about how we use your personal information that are not answered here, or if you wish to complain to our Data Protection Officer, please contact us:
- By email at info@jlmoney.co.uk
- By phone on +44 (0)20 3302 4020
- By letter at JL Money, Melbury House, 34 Southborough Road, Bromley BR 2EB
Who we are
- Throughout this Privacy Policy “we” or “us” means Jeremy Lawrence Ltd.
- JL Money is a trading name Jeremy Lawrence Ltd.
- The website www.jlmoney.co.uk is owned and operated by us.
- Jeremy Lawrence Ltd is the data controller under the General Data Protection Regulations. This means we are responsible for determining the purpose and the means used to collect, store and use your personal information.
The information we process
- Personal information means information about a living individual who can be, directly or indirectly, identified from that information (either by itself or when it is combined with other information).
- We obtain and process various types of personal information at the start of, and for the duration of, and after your relationship with us.
- We limit the collection and use of information to what is necessary to achieve one or more specified purposes as identified in this policy.
- Personal information may include:
- basic information, such as name, address, nationality, and date of birth
- contact information such as telephone numbers and email address
- financial information, including account and card details and transactional history
- information about your social circumstances such as marital or residential status
- information about your financial circumstances, including
- personal wealth
- assets and liabilities
- income and expenditure
- credit and borrowing history
- tax returns
- loan purpose;
- employment information and information about your business
- visual images and personal appearance such as copies of passports;
- details of loans you have had with us
- For secured loans we obtain the following additional information:
- property portfolio information including outstanding loans and charges
- legal and financial information from solicitors and accountants
- We may also collect, store and use certain special categories of information (i.e. sensitive personal information) for specific and limited purposes such as physical or psychological health details or medical conditions.
- We will only collect, store and use special categories of information where we’ve obtained your explicit consent or are otherwise lawfully permitted to do so.
- We may collect, store and use information to perform checks, to prevent and detect crime, and to comply with laws relating to money laundering, fraud, terrorist financing, bribery and corruption, and international sanctions.
How we obtain information
- We obtain information about you in a number of ways.
- We obtain information from you, such as:
- information you provide through our websites and applications
- information you provide when you communicate with us by phone or email
- information you provide through documents you send or give us
- We obtain information from third parties such as:
- credit reference agencies
- fraud prevention agencies
- solicitors and accountants (for secured loans)
- debt collection agencies
- We may obtain information through our relationship with you, such as:
- payments made to your accounts;
- We may obtain information from the technology you use to access our services such as:
- telephone number
- IP address
- (for details on the information collected in this way please see our Cookies Policy)
- We may obtain information from publicly available sources, such as:
- company registers
- online search engines
- Calls to our office may be recorded and monitored for quality and monitoring purposes;
- For more information on how we access information from credit reference and fraud prevention agencies see the section on ‘Credit Reference Agencies (CRAs) and Fraud Prevention Agencies (FPAs)’ below.
Your rights
- You have certain rights in relation to your personal information we process about you.
- We want to make sure you are aware of these rights.
- We describe those rights and the circumstances in which they apply below.
- If you wish to exercise any of these rights, please contact us:
- By email us at info@jlmoney.co.uk
- By phone on +44 (0)20 3302 4020
- By letter at Melbury House, 34 Southborough Road, Bromley BR 2EB
- Access: You have a right to get access to the personal information we hold about you (this is called a Subject Access Request).
- If you would like a copy of the personal information we hold about you, please contact us using the above details. There is no fee for this.
- Rectification: You have a right to rectification of inaccurate personal information and to update incomplete personal information.
- If you believe that any of the information that we hold about you is inaccurate or incomplete, you have a right to request that we rectify the inaccurate personal information.
- Erasure: You have a right to request that we delete your personal information.
- You may request that we delete your personal information if you believe that:
- we no longer need to process your information for the purposes for which it was provided;
- it is used for direct marketing purposes and you object to this use;
- we have requested your permission to process your personal information and you wish to withdraw your consent; or
- we are not using your information in a lawful manner
- Restriction: You have a right to request us to restrict the processing of your personal information.
- You may request us to restrict processing your personal information if you believe that:
- any of the information that we hold about you is inaccurate
- it is used for direct marketing purposes and you object to this use. We will restrict the usage of your personal information for marketing purposes whilst we investigate whether we have legitimate grounds to this use of your personal information
- we no longer need to process your information for the purposes for which it was provided, but you require the information to establish, exercise or defend legal claims; or
- we are not using your information in a lawful manner and you prefer that we restrict how we use your personal information as opposed to delete your personal information
- Portability: You have a right to data portability.
- Where we have requested your permission to process your personal information or you have provided us with information for the purposes of entering into a contract with us, you have a right to receive the personal information you provided to us in a portable and machine-readable format such Excel or CSV.
- You may also request us to provide it directly to a third party, if technically feasible. We’re not responsible for any such third party’s use of your account information, which will be governed by their agreement with you and any privacy statement they provide to you.
- If you would like to request the personal information you provided to us in a portable format, please contact us using the details above.
How we use your information
- We want to ensure that you fully understand how your information may be used.
- Below, we describe in detail the purposes for which your information may be used.
- We use your information where necessary to carry out our lawful business activities.
- This includes processing your information because:
- it is necessary to enter into or perform a contract with you (contractual basis)
- we are legally required to do so (legal basis)
- we have a legitimate business interest to do so (legitimate interest basis)
Contractual basis
-
- We may process your information where it is necessary to enter into a contract with you.
- And we may process you information to perform our obligations under that contract.
- This may include processing information to:
- assess and process applications for our products
- collect and issue all necessary documentation
- open, set up, operate, manage and close your accounts
- make payments to you or to third parties
- process transactions
- manage your account
- communicate with you about your accounts
- execute your instructions
- agree repayment options
- resolve any queries or discrepancies
- We may perform data analysis, data matching and profiling to support decision-making.
- Application decisions may be taken based on solely automated checks of information from credit reference agencies and our internal records.
- You have the right to obtain human intervention in the credit decision process (if it is by automated decision-making), appeal if your application is refused by automated decision-making and to express your views in relation to the same.
Legal basis
- We are required by law to collect and process certain personal information about you.
- This may include processing information to:
- confirm your identity and address
- assess affordability and suitability of credit
- carry out checks to prevent and detect crime
- comply with laws relating to:
- money laundering
- fraud
- terrorist financing
- bribery and corruption
- international sanctions.
- investigate and gather intelligence on suspected financial crimes, fraud and threats
- (this may require processing information about criminal convictions and offences)
- analyse customer data for regulatory reporting
- help recover funds that have accidentally entered your account
- (as a result of a misdirected payment by a third party)
- deliver mandatory communications to customers such as notices of sums in arrears
- communicate updates to our policies or terms and conditions
- investigate and resolve complaints
- conduct investigations into breaches of conduct and policies by our employees
- perform audits of customer data to manage and improve data quality and integrity
- effectively identify, monitor, manage, and report risks we are exposed to
Legitimate Interest Basis
- We may process your information where it is in our legitimate interests do so.
- We will do this without prejudicing your interests or fundamental rights and freedoms.
- We have a interest to process your information in the day-to-day running of our business:
- to determine what products and services we can offer
- to determine the terms on which we offer products and services
- to ensure that we provide you with the most appropriate products and services
- to ensure that our processes and systems operate effectively
- to ensure that we continually develop and improve as an organisation
- to ensure that we can continue operating as a business
- to manage our business and financial affairs
- to protect our business by preventing financial crime
- to protect our customers, employees and property
- This may include processing information to:
- monitor, maintain and improve internal business processes, information and data
- monitor, maintain and improve technology and communications
- respond to information technology and business incidents and emergencies
- ensure business continuity and disaster recovery
- ensure network and information security
- monitoring authorised users’ access to our information technology
- prevent cyber-attacks, unauthorised use of our systems and websites
- prevent or detection crime
- protect of your personal data
- monitor, manage and mitigate the company’s material risks
- carry out financial and credit risk assessments
- carry out audits and test of systems;
- perform general, financial and regulatory accounting and reporting
- carry out, monitor and analyse our business
- trace debtors and recovering outstanding debt
- protect our legal rights and interests
- identify new business opportunities
- develop enquiries and leads into applications or proposals for new business
- make, or assist in making, credit decisions about you
- check the details that you have let us and others have
- manage and take decisions about your accounts
- develop our relationship with you
- send you relevant marketing information (by SMS, email and post)
- improve our products and services
- develop new products and services
- improve the relevance of products and services
- monitor the performance and effectiveness of products and services
- understand our customers’ behaviour, preferences, needs and expectations
- to assess the quality of our customer services and to provide staff training
- perform analysis on customer complaints to prevent future errors and failures
- to resolve complaints and rectify negative impacts on customers
- carry out market research, business and statistical analysis
- to share data with credit reference and fraud prevention agencies
- to share date with law enforcement agencies
- comply with our regulatory obligations
- enable a sale, reorganisation, transfer or other transaction of our business
- For more information on how we use information from credit reference and fraud prevention agencies see the section on ‘Credit Reference Agencies (CRAs) and Fraud Prevention Agencies (FPAs)’ below.
Who we share your information with
- We will keep your personal information confidential and secure.
- We will only share it with others for the purposes explained in this policy.
- We have trusted relationships with selected third parties who perform services for us.
- All service providers are bound by contract to maintain the security of your personal information and to use it only as permitted by us.
- We will not share your information with anyone except:
- where we have your permission
- where required for your product or service
- with third parties providing services to us such as solicitors, accountants and other professional service providers
- with agents and sub-contractors acting on our behalf
- with credit reference and fraud prevention agencies
- with third-party guarantors or other companies that provide you with services
- with debt collection agencies;
- with any payment system we may use;
- where we are required by law or by legal, governmental or regulator entities
- where we suspect funds have entered your account as a result of a financial crime
- where required for a proposed sale, reorganisation, or transfer, of our business
- with certain authorities in order to detect and prevent terrorism
- with third parties in anonymised form as part of statistical or aggregated data such as data analytic companies
- with any person who we reasonably believe to be handling your own affairs because of mental capacity or other similar issues
- where permitted by law, it is necessary for our legitimate interests or those of a third party, and it is not inconsistent with the purposes listed above
- For more information on how we share information with credit reference and fraud prevention agencies see the section on ‘Credit Reference Agencies (CRAs) and Fraud Prevention Agencies (FPAs)’ below.
Credit Reference Agencies (CRAs) and Fraud Prevention Agencies (FPAs)
- We may access and use information from credit reference and fraud prevention agencies
- We may access this information when you apply for a loan or during your loan to:
- assess affordability and avoid customers becoming over-indebted;
- assess your creditworthiness
- check your identity and verify the accuracy of the information you provide to us
- prevent criminal activity, fraud and money laundering
- trace debtors and recover debts.
- To help us make decisions on when to give you credit, we use a system called credit scoring to assess your application. To work out your credit score, we look at information you give us when you apply; information from credit reference agencies that will show us whether you’ve kept up to date with payments on any credit accounts (that could be any mortgages, loans, credit cards or overdrafts), or if you’ve had any court action such as judgments or bankruptcy; your history with us such as maximum level of borrowing; and affordability, by looking at your available net income and existing debts.
- We will continue to share information with credit reference agencies about how you manage your account including your account balance, payments into your account, the regularity of payments being made, credit limits and any arrears or default in making payments, while you have a relationship with us. This information will be made available to other organisations (including fraud prevention agencies and other financial institutions) so that they can take decisions about you, your associates and members of your household.
- If false or inaccurate information is provided and/or fraud is identified or suspected, details will be passed to fraud prevention agencies. Law enforcement agencies and other organisations may access and use this information.
- If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the products or services you have requested, or we may stop providing existing services to you.
- A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. Fraud prevention agencies can hold your information for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.
- When credit reference and fraud prevention agencies process your information, they do so on the basis that they have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect their business and to comply with laws that apply to them. It may involve investigating and gathering intelligence on suspected financial crimes, fraud and threats and sharing data between banks and with law enforcement and regulatory bodies.
- If you would like a copy of your information held by the credit reference and fraud prevention agencies we use, or if you want further details of how your information will be used by credit reference agencies, please visit their websites.
Protecting your information
- We recognise how important it is to protect the information you share with us.
- We are committed to keeping your personal information confidential and secure.
- We use computer safeguards such as firewalls and data encryption.
- We enforce physical access controls to our buildings and files.
- We only authorise access to those employees who require it to fulfil their responsibilities.
- We protect data shared with us through the website using secure socket layer encryption.
- Our security systems meet or exceed industry standards.
- We are constantly monitoring developments to ensure our systems evolve as required.
Transfer of Information
- We may transfer your personal information abroad to other countries outside the EEA.
- If we do so, we will ensure the information is held securely to standards at least as good as those in the UK and only used for the purposes set out in this Privacy Policy. The measures we will take to ensure the security of your personal information may include obtaining a contractual undertaking from the non-EEA third party that they will keep your personal information secure.
How long we hold your information
- We will hold your data on our systems as follows:
- if you have taken out a loan – 7 Years
- if you have had a loan declined – 3 Years
- all other scenarios – we will hold your personal information for marketing purposes unless and until you object to this use of your personal information . Please note that you can unsubscribe to any marketing communications by clicking unsubscribe from any marketing communication you receive from us or by calling us on 020 3302 4020 or emailing us at info@jlmoney.co.uk.
Third-party links & social media features
- Our site may contain links to third party websites.
- If you follow a link to any of these websites, please note that these websites have their own terms and privacy policies and that we do not accept any responsibility or liability for them.
- Our website includes Social Media Features such as the Facebook Like button.
- These Features may collect your IP address, which pages you are visiting on our site and may set a cookie to enable the Feature to function properly.
- Social Media Features and Widgets are either hosted by a third party or hosted on our site.
- Your interactions with these Features are governed by the privacy policy of the company providing it.
Changes to our Privacy Policy
- We may change the way we use your information from time to time.
- We regularly review our Privacy Policy to make sure it is up-to-date.
- We may update our Privacy Policy to make sure we continue to serve your interests.
- When we do we will publish the updated Privacy Policy on our website.
- We encourage you to visit our website regularly to stay informed on our Privacy Policy.
Contact us
If you have any queries about how we use your personal information that are not answered here, or if you wish to complain to our Data Protection Officer, please contact us:
- By email at info@jlmoney.co.uk
- By phone on +44 (0)20 3302 4020
- By letter at JL Money, Melbury House, 34 Southborough Road, Bromley BR 2EB
Contacting our regulator
- You have a right to lodge a complaint with the regulator.
- We hope that we can address any concerns you may have.
- But you can always contact the Information Commissioner’s Office (ICO).
- For more information, visit ico.org.uk
Updated May 2018