Jump to section
- Who are we?
- Our Service
- How do we collect your personal information?
- What personal information do we collect about you?
- How do we use your personal information?
- Purposes for which we use your personal information
- How long do we keep your personal information for?
- Who do we share your personal information with?
- Automated Decision Making
- What are your legal rights?
- Is your personal information transferred outside the EEA?
- Data Security
- Complaints and contact details of our data protection officer
1. Who are we?
We (Digitonomy Limited) are a credit broker, authorised and regulated by the Financial Conduct Authority (FRN 690249). Clever Loans is one of our trading styles, and we host this website. We are based in Chester, and our registered office is at the Steam Mill Business Centre, Steam Mill Street, Chester, Cheshire, CH3 5AN. Our registered company number is 08385135. We are registered with the Information Commissioner's Office with registration number ZA007309.
“Personal information” in this policy means any information that we collect that could identify you such as for e.g. your name, address and online identifiers like your IP address.
3. Our Service
When you ask us to search for a financial service or product, we will use the personal information you provide to us in the following way to deliver “Our Service:”
- We are a data controller in relation to the personal information you have given to us, and we store this in a UK data centre;
- We then share your information with our panel of financial services firms who are authorised to provide the particular product or service you are looking for, (“Our Partners”);
- Our Partners are separate data controllers when they receive this information, and they may process for their legitimate interests to see whether they can provide you with the financial service or product you are looking for. For example, if you are enquiring about a loan or a credit card, Our Partners will carry out loan eligibility assessments and make automated decisions about you such as soft searches. (Please see point 10 below for more information about this and what rights you may have as a result.)
- If any of Our Partners are not able to help you, they may need to retain your personal information for a period of time (usually 12 months) so that they can use it to support their legal and regulatory obligations and their legitimate interests such as fraud and credit analysis. This also enables them to match any subsequent applications you might make during this time against the personal information held to ensure they do not credit search you unnecessarily.
- If one of Our Partners is able to help, you will be re-directed to their website to complete your application.
- We will stay in contact with you about your enquiry and about any of our similar products and services (unless you have asked us not to) using the contact details you have given to us.
4. How do we collect your personal information?
We collect personal information from you in the following ways:
4.1 Information you give us:
- Information you give us when you complete any online forms on our website to use Our Service.
- Information you provide when corresponding with us by phone, email or other means. This includes information you might give us when using Our Service, or if you need to ask us a question, report a problem with our site or if you otherwise contact us.
4.2Information we collect from you:
5. Personal information we collect from you:
In order to provide Our Service, we need to collect the following personal information about you:
Identity information: this includes your first and last name, and your date of birth.
Contact information: this includes your address; telephone number(s), and your email address.
Financial information: this includes details of your bank account; income and expenditure; the amount of money you are looking to borrow; the length and purpose of the loan; the date you are paid each month, and whether you have a debit card.
Employment information: this includes your employment status; the name of your employer; your job title, and the time you have been in your current job.
General information: this includes your home owner status, your marital status and the number of any dependents you may have.
Marketing and communications information: this includes your preferences in receiving marketing information about our similar products and services.
Technical information: this includes your internet protocol (IP) address used to connect your computer to the internet; your browser; time zone setting; your operating system and platform; the source of your enquiry (for example Google, Facebook, Bing etc) and the device that you are using. We also collect information about your visit to our site including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including the date and time); page response times; download errors; lengths of visits to certain pages; page interaction information (such as scrolling; clicks and mouse-overs); methods used to browse away from the page, and, if you linked to our site from a search engine, the address of that search engine and the search term you used.
Please note: it is your responsibility to check and ensure that any information you provide is correct, complete and accurate. If you fail to provide your personal information where requested, we will not be able to provide you with Our Service.
6. How do we use your personal information?
We will only collect and use your personal information when the law allows us to. Most commonly, we will use it in the following circumstances:
Where it is necessary for our legitimate Interests (or those of a third party): we may process your personal information for the legitimate interests of our business (or those of a third party) in providing Our Service to you, providing these interests do not override your privacy in any way. Our legitimate interests for processing your personal information are:
- The interests of our company in conducting, managing and improving our business. As a result, Our Service enables us to help you find the product or service you have expressed an interest in applying for. You will be contacted with this information, and (unless you have asked us not to) we will also send you information about our related products and services using the contact details you have provided. (Our right to do this is known as the “soft opt-in.” This is explained in more detail below.) Using your personal information in this way is an essential part of us being able to provide Our Service to you.
- To improve Our Service. To achieve this, we will use your personal information: to customise certain features of Our Service; for market research, and (if you are searching for a loan), to use our QuickCheck tool. QuickCheck enhances Our Service by enabling customers to assess their chances of being accepted for a loan. This is achieved using aggregated anonymised data that we hold internally and does not involve a soft credit search. (Aggregated anonymised data is data where the person’s identity has been removed and so no one can be identified from it.) We are dedicated to constantly finding ways to improve Our Service and using your personal information in these ways enables us to achieve this.
Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us (for example by submitting your contact details on our website to make an enquiry about Our Service), and we are marketing other similar services. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. For most customers, this is beneficial as it allows us to tell you about other related services that we think would be useful to you alongside the specific one you originally expressed an interest in.
Marketing: we will only contact you in response to a request or communication from you or under the soft opt-in. We will not send unsolicited marketing communications to you about any other types of products or services.
Third-party marketing: we will not share your personal information with any company outside our company for their marketing purposes.
Change of purpose: we will only use your personal information 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.
If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Where we need to comply with a legal or regulatory obligation: we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
7. Purposes for which we use your personal information
We have set out below, in a table format, a description of the ways your personal information could be used by us, and which of the legal bases we rely on to do so. Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To enable you to use Our Service and submit your application form to Our Partners
Necessary for our legitimate interests (to operate our business in providing and improving Our Service.)
To enable you to use our QuickCheck tool to assess your chance of being accepted for a loan
Necessary for our legitimate interests (to operate our business in providing and improving Our Service.)
To enable us to communicate with you:
(a) About your enquiry and any of our similar products and services (unless you have asked us not to) using the contact details you have given to us.
(b) about any enquiries or complaints, you may have.
(c) To ask you to complete a survey or provide us with feedback, testimonials or reviews
(c) Marketing and communications information
(a) Necessary for our legitimate interests (to operate our business in providing and improving Our Service, by remaining in contact with you about your enquiry and our similar products and services.)
(b) Necessary to comply with a legal obligation
To enable us to present you with advertisements about the products and services we provide as a credit broker that we believe will be relevant to you and that you will be interested in, we may use your personal information to create a profile of you and your circumstances. These advertisements may be sent directly from us (unless you have asked us not to), or be presented to you via advertising networks and social media companies such as Facebook, Google and Snapchat for e.g.
We believe we have a legitimate interest to profile your personal information in this way. However, you have the right to object if you do not want us to do this. In this case, please contact us by writing to the Customer Services Manager at Digitonomy Limited, Steam Mill Business Centre, Steam Mill Street, Chester, Cheshire, CH3 5AN, to tell us that you do not want your personal information to be used in this way.
(b) Marketing and communications information
Necessary for our legitimate interests (to provide you with advertisements relating to the products and services we provide as a credit broker either directly or via advertising networks and social media companies.)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer, improve and protect our business and this website (including training, troubleshooting, data analysis, testing, system maintenance, research, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to improve our marketing strategy)
8. How long do we keep your personal information for?
Unless required by law to keep your personal information for a different period of time, we will keep it for no longer than 12 months from the date you last used Our Service or until you ask us to delete it. Please note that if you ask us to delete your personal information it may still remain on our backup systems for legal or other regulatory reasons.
9. Who do we share your personal information with?
When you use Our Service, your information will be shared with the following third parties:
- Our Partners: to help you find the financial product or service you have told us you would like to apply for, and to send you marketing communications if you gave them your consent to this. If you are searching for a loan product, Our Partners comprise a panel of consumer credit lenders and brokers who are authorised and regulated by the Financial Conduct Authority.
- Other companies who enable us to provide Our Service or who provide services to us, for example IT Service Providers (who provide for e.g. technology platforms or other IT services including data storage), and communication providers (who provide for e.g. email and text services for customer contact and marketing purposes).
- Advertising networks and social media companies such as Facebook, Google and SnapChat so that we can present you with relevant advertisements.
These third parties help us to provide Our Service. In order that they can do this, we may need to let them process your personal information. We will make sure that they keep the information secure and in accordance with our instructions, the General Data Protection Regulation 2016 (“GDPR”) and other UK privacy legislation.
We will also share your personal information when we have your consent, or where we are obliged to do so for a legal or regulatory reason, for e.g. to prevent or detect crime, for compliance monitoring or to enforce or apply our Terms & Conditions and other agreements.
10. Automated Decision Making
An automated decision is one where a computer or system is used to assess the information you provide to make a decision about you. We do not make automated decisions about you; however, Our Partners may do this when we share your personal information with them so that they can make an assessment of your eligibility for Our Service. An example of this is the soft search that Our Partners will carry out upon you if you make an application for a loan or credit card.
(Note: a “soft” credit search helps Our Partner to decide whether or not they may be able to lend money to you. Unlike a “hard” credit search, a soft search is recorded on your credit file, but only you rather than any other lender will be able to see it. A soft search does not therefore affect your credit rating.)
As a result, you have the right to ask Our Partners that they do not make a final decision based solely on automated means. You can also object to the automated decision and ask that a person reviews it. If you ask us, we can tell you which of Our Partners has made an automated decision about you. To exercise this right, you will then need to contact Our Partners directly.
11. What are your legal rights?
- Right to Object - because you have asked us to help you find a financial product or service, we need to process the personal information you give us to enable us to find the best product or service available amongst Our Partners. You can object to this processing at any time by sending us an email, or by writing to the Customer Services Manager at Digitonomy Limited, Steam Mill Business Centre, Steam Mill Street, Chester, Cheshire, CH3 5AN. We will action any request you make promptly, although this will mean that we will not be able to help you find the financial product or service that you asked us to search for.
- Right of Access - you can ask us at any time to confirm whether we hold your personal information, and if so you can access it by writing to us at: Data Subject Access Request Department, Digitonomy Limited, Steam Mill Business Centre, Steam Mill Street, Chester, Cheshire, CH3 5AN or by sending us an email.
- Right to rectification - if we hold personal information about you that is inaccurate, you can ask us to correct it, and we will do this as quickly as possible.
- Right to erasure – if it is no longer necessary for us to hold your personal information bearing in mind the reason why you provided it to us, you can ask us to delete it. If you ask us to do this, we will delete your personal information as soon as possible although this will mean that we may not be able to help you find the financial product or service that you asked us to search for.
- Right to restrict our use of your information - you can ask us to restrict our processing of your personal information if you think for example that the personal information you gave us is inaccurate. This may mean that we may not be able to help you find the financial product or service that you asked us to search for.
- Right to complain to the Information Commissioner’s Office (ICO) - we will try to resolve any complaint that you may have in relation to data protection issues. If you are not happy with our final response you have the right to have your complaint dealt with by the ICO. See section 14 for - “Complaints and contact details of our data protection officer.”
12. Is your personal information transferred outside the European Economic Area (“EEA”)?
Although we do not routinely transfer personal information outside the UK, we may sometimes need to do this where any of Our Partners or third-party suppliers are either based outside the EEA, or where they use data processors based outside the EEA. Where this is the case, we will make sure that they agree to: keep your personal information secure; apply the same levels of protection as we are required to apply to information held in the UK, and to use it only for the purpose of providing Our Service. We will do this by putting in place appropriate safeguards and protections as stated under UK law, for example using a data-transfer agreement incorporating certain standard model protection clauses.
13. Data security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
14. Complaints and contact details for our data protection officer
We want you to be confident that we are handling your personal information responsibly and in line with good practice. If you are concerned that we are not doing this, you should contact us immediately. We will treat your concern seriously and work with you to try and resolve it.
Please address your correspondence to:
The Data Protection Officer
The Steam Mill Business Centre
Steam Mill Street
We have implemented and use Google Display Network (GDN) Impression Reporting, Demographics and Interest Reporting, Remarketing with Analytics and Segments.
Whilst we cannot control adverts you may see on other websites, you are free to opt-out of or change your settings regarding ad personalisation at any time, by going to your Google Ads Preferences Manager.
Last updated 11/10/2018