Privacy Policy
Template for review. This template must be reviewed and approved by qualified legal counsel before production use. Sections marked "To be confirmed" need decisions from your legal team.
About this policy
This policy explains what personal information we collect when you create an account, apply for a loan or repay a loan with us, why we need it, how long we keep it and the choices you have.
Information we collect
- Account details: your name, email address, phone number and password. Passwords are stored in a scrambled (hashed) form that our staff cannot read.
- Application details: the amount, term, repayment frequency and purpose of the loan you ask for.
- Personal details: your date of birth, nationality and how you prefer us to contact you.
- Employment and income: your employment status, employer, occupation, monthly income and any additional income you tell us about.
- Address and proof of address: your home address, how long you have lived there and a copy of a document that shows it, such as a utility bill or bank statement.
- Identity document: a copy of the identity document you upload (for example your passport) and its number, issuing country and validity dates. Identity numbers are encrypted and only shown to authorised staff in part.
- Loan and payment records: offers made to you, your loan agreement, repayment schedule and the payments you make.
- Technical information: the IP address and browser details used when you sign in, accept terms or give consent, and security records such as sign-in attempts.
Why we use your information
- To assess your application, including whether the loan is affordable for you.
- To verify your identity and address and to help prevent fraud and financial crime.
- To prepare loan offers, pay out loans, record repayments and send you receipts and reminders.
- To contact you about your application, your loan and your account.
- To keep our service secure and to meet our legal, regulatory and record-keeping obligations.
Legal basis for processing: To be confirmed by legal counsel for the countries where the service is offered (for example performance of a contract, legal obligation, legitimate interests or consent).
Who can see your information
- Our staff, only where their role requires it. Every time staff view or download one of your documents it is recorded.
- Companies that provide services to us, such as hosting and email delivery, under contracts that require them to protect your information.
- Regulators, law enforcement or other authorities when the law requires us to share it.
We do not sell your personal information.
How we protect your information
Uploaded documents are kept in private storage that is not reachable from the internet and can only be opened through our secure website after we check that you are allowed to see them. Identity numbers are encrypted. Access by staff is limited by role and recorded.
How long we keep your information
We keep your information only for as long as we need it for the purposes above and for as long as the law requires us to keep records.
Retention periods: To be configured. The retention period for identity documents, proof of address documents and loan records must be set by the company with its legal team before launch.
Your rights
Depending on where you live, you may have the right to:
- ask for a copy of the information we hold about you;
- ask us to correct information that is wrong or incomplete;
- ask us to delete your information where we are not required to keep it;
- object to or ask us to limit how we use your information;
- complain to your data protection regulator.
You can make a request from the Privacy section of your account, or by contacting us. We may need to confirm your identity before we act on a request.
Cookies
We use only the cookies needed to keep you signed in and to protect forms against misuse. We do not use advertising cookies.
Changes to this policy
The version of this policy is recorded each time you give consent. If we make important changes we will tell you before they take effect.
Contact us
If you have a question about this policy or your information, please use the contact details on our Contact page.