Credit Kudos is a credit reference agency that provides services that help consumer credit firms, identity verification companies, banks, and financial institutions (“Institutions”) to conduct income verification, identity verification and credit checks. The controller for personal data involved when you register to use Credit Kudos, visit your account or communicate with us is:
Credit Kudos Limited, The Print House, 18 Ashwin Street, London E8 3DL (“Credit Kudos”/“we”/“us”/”our”).
Institutions who use our credit checking services are also data controllers. If you have questions about how an Institution handles your personal data, or if you wish to exercise your rights for the personal data they hold, please contact them directly.
We want you to obtain personalised experiences anytime, anywhere, on any device. This requires us to collect personal information from you. However, we want to put you in control of that personal information. We want you to be aware at all times where and how your personal information is being used. This is of paramount importance to us.
So, let’s describe what this Policy tells you. It explains:
- what information we may collect about you;
- what we may do with the information we collect about you;
- whether we share your information with anyone else;
- the types of cookies we use and how you can reject these cookies;
- where we store your information;
- how we keep your information secure; and
- your rights in relation to your information.
At Credit Kudos we take your privacy seriously. We operate on the principle that your personal information belongs to you and only you can decide who you want to share it with and why. This is fundamental to the way we work and we’re committed to providing a secure environment for you to store your personal information and share it with others when you want to.
WHEN DOES THIS POLICY APPLY
HERE IS THE INFORMATION WE MAY COLLECT ABOUT YOU
Information you voluntarily provide
- If you contact us (by phone, email or through the Platform), we may keep a record of that correspondence for two years in case we need to contact you in relation to the issue for which you contacted us, for operational performance improvement and/or nuisance caller management. We will not use it for marketing purposes.
- If you report a problem with the Platform and/or the Services, we may keep that information for two years in case we need to contact you in relation to the issue you for which you contacted us, for operational performance improvement and/or nuisance caller management. We will not use it for marketing purposes.
- As part of the credit checking process , you may provide us with details to enable us to access your bank and credit card accounts. We keep that information for two years from your last interaction with the Platform and/or Services.
- We access, copy and otherwise process the transactional data contained within your bank and credit card accounts.
You should be aware that, depending on the nature of the payors and payees disclosed in your transactional data, we may be made aware of your ethnic origin (eg if you have a subscription to The Irish Times), political opinions (eg, if you pay annual membership fees to a political party), religious or philosophical beliefs (eg if you make donations to a place of worship), trade union membership (eg if you make subscriptions to a trade union), sex life (eg if you have direct debits to certain websites), sexual orientation (eg if you pay membership fees to certain organisations) or health (eg. if you make regular payments to a particular hospital). We will obtain your explicit consent to process this type of data.
The information you give may include your name, address, telephone number, email address, bank and credit card account details as well as passwords and credentials that the bank or credit card provider uses to identify you.
Information we collect about you and your device
When you use the Platform and interact and with our Services, we may use technology such as that provided by Google Analytics to collect information about your visit to our Website. You can find more information about Google Analytics here. In essence, Google Analytics enables us to analyse how you and others interact with our Platform. The information we collect may include:
We are authorised and regulated by the Financial Conduct Authority as a Credit Reference Agency (reference number 770345). As such, when you use the Platform and interact and with our Services, we may receive outcome data from third parties related to your financial standing. In essence, this means we will collect information about any applications you make to financial services companies via the Platform. The information we collect may include:
- your IP address;
- the type of browser you use (e.g. are you using the Chrome or Safari browser?); and
- the number of sessions per browser on each device;
- the type of device (eg Samsung) and operating system (eg Android) you are using;
- referrer information;
- time zone;
- user preferences; and
- which pages you visited.
- whether or not a credit product was granted;
- whether you repaid that credit product or not; and
- whether you are in arrears or default.
THIS IS WHAT WE DO WITH THE INFORMATION WE COLLECT ABOUT YOU
We use the information you provide to us to:
- with your explicit consent, retrieve your transaction history from banks and other credit providers to enable us to provide the Services;
- consolidate and categorise your transaction data to show to the Institution to whom you have applied for credit, so that such Institution can make a decision about whether to approve the credit to you and on what terms. We also store your transaction history and collect repayment information to assist Institutions to make decisions on your credit risk;
- consolidate personal data about you that’s part of, derived from or used in credit activity, including: credit reporting and affordability checks; verifying data like identity, age and residence to preventing and detect criminal activity, fraud and money laundering; account management; tracing and debt recovery; screening; and statistical analysis, analytics and profiling;
- We have a legitimate interest in doing this so as to:
- promote responsible lending and helping prevent over-indebtedness,
- help prevent and detect crime and fraud and anti-money laundering services and to verify identity
- support tracing and collections; and
- comply with and support compliance with legal and regulatory requirements.
- ensure that content from our Platform is presented in the most effective manner for you and for your device to achieve the most user-friendly navigation experience;
- with your consent, provide you with marketing information about us and our services;
- notify you about changes to the Platform and the Services; and/or
- defend our servers against malicious attacks.
Where we propose using your personal information for any other uses we will ensure that we notify you first. You will also be given the opportunity to withhold or withdraw your consent for the use of your personal information for purposes other than those listed above.
OUR USE OF AGGREGATED AND ANONYMISED INFORMATION
We may provide aggregate user statistics and other usage data which does not identify you specifically with third parties. We may combine your data with those of other users of our Platform and share or provide this information in aggregated and anonymised form with third parties. For example, if we establish that users who obtain their gas and electricity from the same energy retailer are less likely to default on a loan then we may share such information with loan providers, but we would only ever do this with anonymised and aggregated data from which it would be impossible to identify an individual.
We may also use information collected from you and combine it with information provided by other users of our Platform to help us improve the design and delivery of our software tools, increasing the effectiveness for all users.
THIS IS WHO WE SHARE YOUR INFORMATION WITH
We will only share information with other organisations where we have your permission to do so in accordance with this Policy or where we believe it is necessary for a legitimate reason connected with the Platform or our Services.
We share personal data with third parties in a transaction to provide our credit reference agency services. We work with analytics providers, banks and other credit providers and we may receive information about you from them. We also work with Twitter, Google, Facebook and LinkedIn to allow you to register for the Services using the credentials that you have with those companies. Below is a non-exhaustive list of third parties we work with. We may work with third parties not listed below or stop working with the third parties listed below.
In addition, we may disclose your personal information to third parties:
- if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request;
- to protect the rights, property or safety of our Platform or our users.
Cookies are small pieces of data that are stored on your computer, mobile phone or other device. Pixels are small blocks of code on web pages that do things like allow another server to measure viewing of a Web page and are often used in connection with cookies. HTML5 Local Storage is a small database located inside your browser which web pages can use to store data to speed up their processing. We may use all three technologies from time to time, to help improve your browsing experience.
We have outlined below the individual cookies we use and why we use them:
THIS IS WHERE WE STORE YOUR INFORMATION
The data that we collect from you may be processed outside the European Economic Area (EEA) (for example if a bank from which you are applying for a loan needs to seek authorisation from one of its subsidiaries overseas). Some of our service providers are located in the United States or other countries that do not provide the same standard of data protection as the EU. Where we work with a service provider, we look for a legal mechanism that requires them to protect data to EU standards. For example, the service provider has signed on to the EU-US Privacy Shield, operates under EU-approved binding corporate rules, or is in a country the EU recognises as having adequate data protection laws. Where no other legal mechanism exists, we enact the EU-approved standard contractual data protection clauses in our contracts.
KEEPING INFORMATION SECURE
All information you provide to us is stored on servers owned and operated by Amazon Web Services, Inc. More information on this provider is available at https://aws.amazon.com.
HERE ARE YOUR RIGHTS
Most of the data we collect and the purposes we use it for are necessary for us to operate and improve our services or comply with our obligations as a credit reference agency. We tell you in the service where you can make a choice or grant consent. When you grant consent, you may withdraw it at any time to stop any further processing. You can also ask us at any time not to send or to carry out profiling for direct marketing, or to stop using certain kinds of cookies.
You may have certain rights under data protection law. These include the right to ask us for a copy of your personal data, to correct, delete or restrict processing of it, and to obtain personal data in a format you can share with a new provider. You may have the right to object to processing. These rights may be limited in some situations - for example, where we can demonstrate that we have a legal requirement to process your data.You can exercise your data protection rights by contacting us at firstname.lastname@example.org. We will require you to prove your identity with 2 pieces of approved identification.
If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live or work, or where you believe a breach may have occurred.
If you want to stop using the Platform and the Services, you may do so. If you do, you may also want to remove any cookies that we have placed on any device used to access the Platform and the Services.
THIRD PARTY PROPERTIES ACCESSED FROM THE PLATFORM
Our Platform and Services may contain links to and from the online properties of third parties. If you follow a link to any of these online properties, please note that these online properties have their own privacy policies which will govern use of any personal data that they process. Please check these policies carefully before you click on any links and/or submit any personal data to these online properties.
CHANGE OF CONTROL
If the ownership of our business changes, we may transfer your information to the new owner so they can continue to operate the Platform and provide the Services. The new owner will be obliged to comply with this Policy.
CHANGES TO OUR POLICY
Any changes we may make to this Policy in the future will be posted on this page. Where it makes sense because the changes are material, we will notify you of the changes by e-mail or in another appropriate manner such as when you next interact with the Platform.
CONTACTING US IS EASY AND WE WANT TO HEAR FROM YOU
We really do welcome any questions, comments and requests you may have regarding this Policy. You can contact us by emailing us at email@example.com.