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How we use your Personal Data

Like other financial organisations, we are legally obliged to collect, verify and record information confirming client identity and to report details of suspicious transactions to the Serious Organised Crime Agency. For more details, please contact us.

For details of the main credit reference agencies we use, please contact us.

1. We may use credit scoring methods to assess your application and verify your identity. Members of our group and other companies may use credit searches and other information supplied to us and/or the credit reference agencies about you and someone linked financially with you, including previous and subsequent names, to make credit decisions about you or other members of your household. Any of this information may also be used for identification purposes, debt tracing, preventing money laundering and managing your account.

2. We may disclose any information you provide to us to a licensed credit reference agency that may retain a record of the search. We will use the results of the search to check your identity and to determine your creditworthiness, although we will not extend a line of credit to you.

3. We have systems that protect our clients and ourselves against fraud and other crime. Client information can be used to prevent crime and trace those responsible. We may check your details with fraud prevention agencies. If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information. We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:

Checking details on applications for credit and credit related or other facilities;
Managing credit and credit related accounts or facilities;
Recovering debt;
Checking details on proposals and claims for all types of insurance;
Checking details of job applicants and employees.

Please write to us if you want details of those credit reference agencies and fraud prevention agencies from whom we obtain and with whom we record information about you. We and other organisations may access and use from other countries the information recorded by fraud prevention agencies. You have a legal right to these details.

4. Occasionally we search credit reference and fraud prevention agency files as well as our own internal group records to manage your account and take decisions such as whether to offer or continue to offer our service. Lenders who may assess your ability to obtain credit may see these searches.

5. ‘Associations’ linking your financial records may be created on Credit Reference Agency records when you apply for accounts in joint names. Your financial records, and those of anyone financially associated with you, may be considered in any future applications you make.

Data Protection

6. The Data Protection Act puts obligations on users of personal information and lays down principles for its use. One principle states that information has to be processed fairly and lawfully. This means that you are entitled to know how we intend to use any information you provide. You can then decide whether you want to give it to us. To provide outstanding client service, we need accurate client information. You can help by informing us whenever your circumstances change. Organisations must lodge a notification with the Information Commissioner describing the purposes for which they process personal information. The details are publicly available from the Commissioner’s office at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Tel 01625 545745. Fax 01625 524510. Alternatively, see the Commissioner’s website:

7. Our main use of your personal information is to look after your account or to provide the specific service you require. We may use your details to inform you by letter, telephone, e-mail, Short Message Service (SMS) or otherwise about any special offers, products or services offered by us and selected third parties, unless you ask us not to do so. If you do not wish to hear about these, please call us or let us know by any means available to you. Remember, however, that opting out could stop you hearing about our special offers or products and services which may benefit you. You agree that we have your permission to contact you on any telephone number that you have provided.

8. Unless you have given us your consent, we will not provide information about you to companies outside Smart Exchange to use for their marketing purposes. We disclose personal information only with your consent, or if we are required to do so by law. Sometimes we need to give information to our agents and subcontractors so that they can provide a particular service for us. Sometimes, these companies may be located abroad in countries that do not have data protection laws. In these circumstances we always take great care to ensure that your personal information is kept safe and secure.

9. We may use your account details, transactions and information provided to us by third parties in our client contact programme.

10. If you provide us with your e-mail address or mobile phone number, we will keep a record of these. We may use them to contact you occasionally about our products and services unless you ask us not to do so. We will not give your e-mail address or mobile phone number to any third parties other than those detailed in paragraph 8.

11. We may record telephone conversations to fulfill regulatory record-keeping requirements, offer you additional security, resolve complaints and improve our service standards. Conversations may also be monitored for staff training purposes.

12. If you send us e-mail over the Internet, remember that it will be ‘unsecure’ and could be intercepted. If you do send us ‘unsecure’ e-mail, please keep the amount of confidential information you include to a minimum. We will do likewise when we reply.

13. Certain information we may collect may be classified as sensitive and we can only use such data where we have your explicit consent. This data relates to racial or ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, sexual orientation, criminal proceedings and offences and will only be processed in order to provide the service requested.

14. Under the Data Protection Act you have the right of access to information we hold about you on our records. The Act allows us to charge a fee of £10 for this service. If anything is inaccurate or incorrect, please let us know and we will correct it.

15. We may disclose any information that we have about you or your account to any governmental or regulatory body entitled by law to that information.

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