We’re committed to keeping your details safe and confidential, and we promise to only use your details when it’s appropriate to do so. This policy will explain how, why and when we will use your personal information, and what we will use it for.
Our lawful basis to process your information
- We will collect your consent in order to process your information for marketing purposes, this includes contacting you about our product, borrowing more money and our offers.
- Where you discuss sensitive data with us, we will capture explicit consent from you in order to store and process this information about you.
- Where you have applied for a loan with a loan brokerage company and they have passed your information to us, we will use our legitimate interests to contact you about the application we have received on your behalf and process your information in line with the loan you have enquired about.
- If you have applied to guarantee a loan we will use our legitimate interests to contact you about the application and process your information about the loan you have applied to guarantee.
We will also process your information as per our contractual and legal obligations to ensure we’re lending safely, responsibly and legally. This includes;
- Performing adequate checks to confirm your identity and to ensure your suitability and affordability for a loan or to guarantee a loan
- Protecting and preventing criminal activity (i.e fraud, money laundering)
- Managing the loan and recovering the debt you owe us (incl. via court proceedings)
- Reporting repayment history to the credit reference agencies
- Responding to and complying with our regulatory requirements (i.e Financial Conduct Authority, Financial Ombudsman Service)
How will we collect your information
- Information you provide to us through our website, the Amigo app and any communication with us
- Information you provide to a loan broker that is passed to us (with your consent)
- From third parties, such as banks, credit reference and fraud prevention or investigation agencies, or any other company that helps us make lending decisions, assessments or credit-related decisions.
- In customer surveys
What information will we collect
We will collect any information we need from you in order to process your application and to manage your loan repayments, as well as any other information which we reasonably need to operate your account, make decisions about you or fulfil our regulatory obligations.
- Your name, date of birth, addresses and contact information
- Your affordability (income and expenditure)
- Card and bank account information. If you provide us with any debit card and bank details, either during the loan application or subsequently, we will keep those details and will use the details in line with the consent you provide to us, unless you advise us otherwise.
- Documents to verify your information (bank statement, payslip, homeownership and identification)
- Information we receive when making a decision about you, your loan or application (including information collected from the Credit Reference Agencies)
- Details of the loans you have and have had with us and all transactions;
- Details of when you contact us and when we contact you;
- Any email address or phone number(s) that you communicate with us on
- If a card is identified as having been used fraudulently then we will maintain a record of its use for reporting and preventing fraud
- We may be given sensitive information such as medical information. We will hold and process this information to allow us to make decisions about you and your accounts with us.
- Your location
- Information about your computer including your IP address, operating system and browser type. For more details please see our Cookies Policy.
- We may record your customer journey on our website or app for usability monitoring, testing and improvement. However, we will not record any personal information you input.
- We will record and/or monitor the calls, texts, emails and letters you send to us or receive from us.
We will also collect information for the purpose of staff training, and system improvement.
How will we use your information
We will use your information to process the loan you have applied for or applied to guarantee, and to manage your account, or the account you guarantee with us.
- To make, or assist in making, credit decisions about you, assess lending risks, and to check the details that you have let us and others have;
- To operate and manage your account and any application, agreement or correspondence you may have with us
- To identify, prevent, detect or tackle fraud, money laundering and other crimes
- Contact you via email, SMS, letter, telephone or send you push notifications about managing your loan with us, including if you fall into arrears or if we have out of date information.
- To contact you about our products and services, unless you tell us that you prefer not to receive marketing
- To collect and manage payments, and to recover any debt you owe us both on your current loan and on any previous or subsequent loans, unless you advise us otherwise.
- To manage interest on your account.
- To respond to complaints
- To exercise our rights set out in agreements or contracts and to comply with our regulatory obligations.
- To detect, investigate, report, monitor and analyse our business
- To carry out market research, to develop and manage our brand, product and services.
- To carry out internal and external audits
- To test our processes and systems
- To obey laws and regulations that apply to us
- To manage security and risk for us and you.
Where you have consented for your details to be passed to us by a loan broker that we work with, and they have notified Amigo that you are looking for a loan, we will store and process your information so you have the option to complete your application without having to re-enter in your details and so we can contact you about our product and let you know what loan options are available to you.
How long we will store your information
- If you have an application with us, we will store your information for 3 months, 1 year or 2 years depending on your individual circumstances (providing we have no reason to keep your data).
- If you have a loan with us, we will keep your information indefinitely until your loan has settled. Once your loan has settled, and providing we have no ongoing relationship with you or any reason to keep your data, we will remove your information after 4 years.
Who we will share your information with
- Manage your applications, accounts and services
- Respond to your queries and complaints
- Collect what you owe
- Explore new ways of doing business
- Audit our internal processes
- Test our systems
- Your guarantor / borrower on your loan
- Companies who verify your information for us
- Credit reference and fraud investigation or prevention agencies
- Organisations that introduce you to us (loan brokers)
- Companies you ask us to share your data with
- When we are legally obliged to, for example, to the courts to recover money your owe us, respond to your complaints via the Financial Ombudsman Service or to the police for criminal activity.
- Third party companies who help us document, record, assess and test our internal processes and systems
- Any company we use to process your information (i.e mail and telecom companies to send you communication via text, email and letter)
- Our regulators
- If you have a debit, credit or charge card with us, we will share transaction details with companies which help us to provide this service (such as Visa and Mastercard).
- If you use direct debits, we will share your data with the Direct Debit scheme and its members.
- Any companies that we transfer your loan to.
- If we use services provided outside of the EEA there will be measures in place to make sure the recipient protects the data to the same standard as the EEA. We will only send your data outside of the EEA to follow your instructions, comply with a legal duty or work with suppliers who help us run your accounts or services.
When you apply for an Amigo Loan, we will look at your credit file at credit-reference agencies ("CRAs") such as Call Credit, Equifax or Experian. The CRAs will give us credit information about you including information from the electoral register. If you’re a borrower, this credit search is used to check your identity and your eligibility for a loan. If you’re a guarantor, this information will be used to check your identity and make credit decisions about you. The CRAs will add details of our searches and your application to the record which they hold about you. If you’re a borrower, the CRAs will also add details of your loan agreement with us, the payments you make under it and any default or failure to keep to its terms. Your credit-reference agency records will be seen by other organisations that make searches with those agencies. Information held about you by the CRAs may already be linked to records relating to one or more of your partners. For the purposes of this application you may be treated as financially linked and your application will be assessed with reference to any “associated” records.
While you are a customer of ours, we may carry out extra credit searches so we can manage your account. We and other organisations may use and search these records (including access and use from other countries) for example to:
- Help make decisions about credit and credit-related services and other facilities for you and members of your household;
- Verify the accuracy of the data you have provided to us;
- Trace debtors, recover debt, prevent fraud, and to manage your accounts and other facilities;
- Check details on proposals and claims for all types of insurance;
- Check details of job applicants and employees; and
- Check your identity to prevent money laundering unless you give us other satisfactory proof of identity.
The identities of the CRAs, 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 here. This information is also accessible from each of the three main CRAs – clicking on any of these three links will also take you to the same document:
How we use your information to make automated decisions
- We use systems to make automated decisions about you to help us make sure our decisions are quick, fair, efficient and correct, based on what we know. Automated decisions can affect the products we may offer you now or in the future. They are based on personal information that we have or that we are allowed to collect from others.
- We use a system to decide whether to lend money to you when you apply for a loan or top up loan. The system will use information from your application form, credit reference agents and data we may already hold about you, including what we have collected from any previous loans you have had with us.
- We use a system that helps us detect fraud and money laundering.
- We may use any data we already hold about you and your payment history with us to help us make decisions on how we should lend to people in the future.
- You have the right to ask us to confirm what information we hold about you at any time, and you may ask us to modify, update or remove your information, providing we are not legally required to hold it or hold it to meet a legitimate expectation or for you or us to meet a legal obligation.
- If we are using your data because we deem it necessary to do so, and you do not agree, you have the right to ask to remove your information, or ask us to stop processing your information. If you would like to do so, you can contact us at [email protected] In cases where you ask us not to contact you, we may still hold your information so that we know not to use it. If you request us to remove your information, we will respond to your request within 30 days. We will only refuse your request if we are required or have legal right to process the information for a specific reason. For example, if you have an ongoing relationship with us, or we have a legal reason to keep it.
- You have the right to object to an automated decision, and ask that a person reviews it. To do this please contact us.
- Where we have obtained your consent to process your personal data for certain activities (for example, marketing), you may withdraw your consent at any time. You can do so by managing your preferences at www.amigoloans.co.uk/optout, or contacting us at [email protected]
- If you wish, you have the right to transfer the data we hold for you. We will help with this – either by directly transferring your data for you, or by providing you with a copy in a commonly used machine-readable format. To do this just contact us by phone, in writing, or by using the email address above.
We recognise how important it is to protect and manage the information you share with us. We use computer safeguards such as firewalls and data encryption to keep your details safe. Our security systems meet or exceed industry standards and we are constantly monitoring internet developments to ensure our systems evolve as required.