In this Privacy Policy the terms, 'we' or 'us' is CreditFocus.

Your privacy is important to us and we are committed to keeping your information secure and managing it in accordance with our legal responsibilities under applicable data protection laws. We are registered with the UK Information Commissioner's Office (ICO) as a data controller under registration number ZA111528.

Please read this Privacy Statement carefully as it contains important information to help you understand how and why we process any personal information that you give to us.

What Information We Collect

We process personal information which you give us:

• Whilst servicing your account through our website, in writing or over the phone.
• If you request information or assistance from us.

What personal information we process

This includes:

• Personal details such as your name, residential address, date of birth, nationality, title, country, credit score, telephone number and email address.
• Identity information such as your unique passport number, driving license number, issue date and expiry date.
• Financial details such as your credit/debit card data.
• Occupation details(employment/self-employment details).
• Cookie data such as browser footprint, CV data, passwords, IP address, call logs, communications metadata, customer service records, security authentication data.
• Transaction history details.

Special Categories of Personal Data

Special categories of personal data include information about an individual's health and other categories of personal information which are closely protected.

We do not generally process such information unless you have voluntarily provided this to us. We will process sensitive information where you have provided this information to us and have agreed that we can use this information to deliver products and services to you. Where possible we shall seek to minimise the collection and use of such special categories of personal data.

How we use your Information

We use your information to:

• Provide and service your relationship with us.
• Comply with legal obligations for the prevention of financial crime and money laundering.

We will process your information in order to meet our contractual obligations to you, were have a legitimate interest to do so, where we are permitted by law or to comply with applicable laws and regulation.

PURPOSE	LEGAL BASIS
Providing a service and internal processing
To assess your needs and provide you with suitable products and services	Contractual obligation to provide you with, or a proposal including a costs estimate Where special categories of personal data are processed, these are necessary to assess your needs
To service and administer your matter including billing	Legitimate interests to provide and manage the service
To verify the identity of our clients	To comply with legal obligations to prevent money laundering
To confirm, update and improve our client records	To comply with legal obligations in the Data Protection legislation
To provide you with any information on the services that you have requested	To meet our contractual obligation to provide information on the services you have requested
Relationship Management
To manage and develop our relationship with you	Legitimate interest to service your matter and improve our service to you
To inform you of products and services that may be of interest to you, where you have chosen to be made aware of this	With your consent
Training and development
For training purposes and to improve our service to you	Legitimate interests to improve our services and develop our employees
Complying with Legal Obligations
To prevent, investigate and prosecute crime, fraud and money laundering	To comply with legal obligations for prevention of financial crime and money laundering
For auditing purpose	To comply with our legitimate interest to conduct audits
If we are obliged to disclose information by reason of any law, regulation or court order	To comply with legal obligations
Other
To transfer information to any entity which may acquire rights in us	Legitimate interests for commercial interests
For any other purpose to which you agree	With your consent

How we retain your personal information

We will retain your personal information in accordance with applicable laws. We will take reasonable steps to destroy or anonymise personal information we no longer need for the purposes we have set out above.

Our retention periods are:

Type of personal Information	Retention Period
General personal data which includes your normal personal data, personal identity and personal financial data	6 years after the end of our business relationship with you, or the end of your matter which ever comes later
Special categories of personal data	6 years after the end of our relationship with you
Call recordings	1 year
CCTV – digital images if you visit our offices	90 days

How we share your information

• We share no personal data with any third parties or regulated authorities.

Information Security

We invest appropriate resources to protect your personal information, from loss, misuse, unauthorised access, modification or disclosure. However, no internet-based site can be 100% secure and we cannot be held responsible for unauthorised or unintended access that is beyond our control.

Updates

We will keep this Privacy Policy under review and make updates from time to time. Any minor changes to this Privacy Statement will be posted on this page and we will communicate any major changes to you.

Cookies

A cookie is a technology for remembering information between web pages. It is the term given to describe a type of message that is given to a Web browser by a Web server. Because of cookies, your web browser can remember you are logged in, or have visited a site before, or what your personal preferences are making your browsing experience better.

Cookies and Tracking technologies: technologies such as cookies, tags and scripts are used by us and our partners (such as advertising, marketing and analytics), affiliates or analytics or service providers. These technologies may be used in analysing trends, administering the Sites, tracking users’ movements around the Sites and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by such companies on an individual as well as aggregated basis. The third-party cookies (stored by a different domain to the visited page's domain) used by us are outlined in the table below. Unless otherwise stated on the site, the data is anonymised.

3rd Party	Purpose	Link to Privacy Policy
Google analytics	Customer analytics	https://policies.google.com/technologies/cookies
Hotjar	Customer analytics	https://www.hotjar.com/legal/policies/privacy
Optimizely	A/B testing	https://www.optimizely.com/privacy/#information-we-collect
Popup Dominator	Popup overlays and exit intents	https://www.popupdomination.com/privacy-policy
Mouse Flow	Form monitoring	https://mouseflow.com/privacy/
Unbounce	Landing pages	https://unbounce.com/privacy/
Appcuse	Onboarding helper	https://www.appcues.com/privacy
Olark	Online Chat	https://www.olark.com/privacy-policy
Freshdesk	Online Chat	https://www.freshworks.com/privacy/
Zoho	Online Chat	https://www.zoho.eu/privacy.html

Some or all of these tools may be used to track information about your behaviour on our website depending on your region. For more information or to opt-out, please visit the respective website(s) of these vendors or contact us at compliance@creditfocus.co.uk.

Your Rights

You have the right to request copies of your personal information. If you think any of the personal information we hold about you is inaccurate, you may also request it is corrected or erased. You also have a right, in certain circumstances, to object to our processing of your personal information, to require us to stop processing your personal information and/or to withdraw your agreement to processing based on 'consent', but this does not apply where we have other legal justifications to continue processing your data or an overriding legitimate interest.

In relation to all of these rights, please write to us at the address below.

Complaints Process

If you have a complaint about how we have handled your personal information you may contact us using the details below and we will investigate your complaint. You also have the right to complain to the Information Commissioner’s Office - (https://ico.org.uk/).

Contact Us

You can contact us by writing to us at:

Data Protection Supervisor, CreditFocus, 6th Floor, 9 Appold Street, London, EC2A 2AP

Or at compliance@creditfocus.co.uk.