Privacy Policy

Please read this Privacy Policy carefully to understand our views and practices regarding your personal data and how we will treat it. By using the services that are set out in our Terms of Use you agree to be bound by this Privacy Policy. You must not use this website or our Services if you do not accept this Privacy Policy. Before providing a third party’s information you should ask them to read this Privacy Policy and our Terms of Use. By giving us information about another person you are confirming that they have given you consent to provide the information to us and that they understand how their details will be used.

1. Who we are

APFIN LTD trading as clearandfair.co.uk ("We") are committed to protecting and respecting your privacy. This policy, together with our Terms of use, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. For the purpose of the Data Protection Act 1998 (the "Act"), the data controller is APFIN LTD with a registered office at 3rd Floor, 12 Gough Square, London, EC4A 3DW. We are registered with the UK Information Commissioner under the Act and our registration number is Z3194688.

2. What information we collect

We may collect and process the following data about you:

• Information that you provide by filling in forms on our site www.clearandfair.co.uk ("our site"), (including your personal information, postcode, phone number and details relating to your requirements);
• Information that you provide to us for the purpose of registering with us, receiving our newsletters, updates and emails (including your email address);
• Information which you provide when we contact you, or when you contact us, via the website, by email, phone, text or post. We may keep a record of that correspondence, including monitoring and / or recording telephone calls.
• Information which you provide when you report a problem with our site;
• Your answers to surveys we may ask you to complete that we use for research purposes, although you do not have to respond to them.
• Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, referral source, length of visit and page views, whether this is required for our own billing purposes or otherwise, and the resources that you access;
• Information about purchases of financial products that you make on third party websites after you follow a hyperlink on our website (including the product purchased, the product provider and the date and time of the purchase);
• Any other information that you choose to send to us (including testimonials, feedback and questions).

We may also collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.

3. Our lawful bases for processing your personal data

Contract
- In order to fulfil our contractual obliations to you, or because you have asked us to do something before entering into a contract

Legal Obligations
- In order to comply with legal and statutory obligations, such as FCA and ICO regulations

Legitimate Interests
- In order to pursue our reasonable commercial interests

Consent
- To offer you any services provided by APFin Limited, or other companies, that we think may genuinely interest you, subject to you providing your consent.

4. Purpose for processing your data

We may use your personal information:

• To enable you to access and use our services;
• To ensure that content from our site is presented in the most effective manner for you and for your computer;
• To send you a confirmation email of your quote;
• To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
• To allow you to participate in interactive features of our service, when you choose to do so;
• To notify you about changes to our service.

When third parties use your data to provide you with products or services, they will be acting as data controllers of your information. If you enter into a contract with a third party through our site, the information you provided to us together with any further information requested by, and supplied by you or us to the third party will be held and used by the third party in accordance with their privacy policy. Therefore, you are strongly advised to read your chosen provider's privacy policy and satisfy yourself as to the purposes for which the provider will use your personal information before entering into the contract. We have no responsibility for the uses to which a provider puts your personal information.

We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in London). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.

5. Retention Period

We will hold the data that you provide for as long as permitted for legitimate business purposes.

We store your data for the following reasons:

• To respond to any questions or complaints;
• To show that we treated you fairly;
• As a record of your application to comply with statutory obligations in relation to FCA regulations;
• For legal reasons.

We will store your data, but no longer process it if you revoke your consent to receiving the offer of the services of other companies within the APFin Ltd family, and other related services, including but not limited to, price comparison websites, that we think may genuinely interest you.

6. Where we store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

All the information you provide us is stored in a secure computing environment protected by secure firewalls to try to prevent unauthorised access. Our website and database of information is held on a secure server. We also control access to any information you provide us so that it is only provided to people who need to see it. When we transfer any of your information it will be password protected.

7. Your rights

• Right to be informed
  • We are obligated to provide fair processing information, typically through a privacy notice, and the information must be concise, transparent, easily accessible and provided free of charge.
• Right of access
  • Individuals have the right to access their personal data and supplementary information.
  • The right of access allows individuals to confirm that their data is being processed and to verify the lawfulness of the processing.
  • We will provide a copy of the information free of charge, however an administrative fee may be charged if the request is manifestly unfounded or excessive.
  • Information will be provided within one month of receipt, however we may extend the period by a further 2 months if the request is complex or numerous.
• Right to rectification
  • An individual’s personal data can be rectified if it is inaccurate or incomplete.
  • Data will be rectified within one month of the request, however we may extend the period by a further 2 months if the request is complex.
• Right to erasure
  • An individual can request the deletion or removal of personal data where there is no compelling reason for its continued processing.
  • We may be unable to fulfil your request for a number of reasons, including: if we need to keep your data in order to respond to any questions or complaints you may have, to show that we treated you fairly, as a record of your application to comply with statutory obligations in relation to FCA regulations, or legal reasons.
• Right to restrict processing
  • Individuals have a right to ‘block’ or suppress the processing of personal data.
  • When processing is restricted, we are permitted to store the personal data, but not further process it.
• Right to data portability
  • Individuals may obtain and reuse their personal data for their own purposes.
  • The personal data will be provided free of charge, in a commonly used format.
  • Information will be provided within one month of receipt, however we may extend the period by a further 2 months if the request is complex or numerous.
• Right to object
  • Individuals have the right to object to processing based on legitimate interests or the performance of a task in the public interest; direct marketing; and processing for purposes of scientific or historical research and statistics.
  • Individuals must have an objection on “grounds relating to his or her particular situation”.
• Rights related to automated decision making including profiling
  • We can only carry out this type of decision-making where the decision is necessary for the entry into or performance of a contract.
• Right to withdraw consent
  • Individuals may withdraw consent for us to process your personal data for marketing purposes at any time.
  • You can exercise your right to withdraw consent by not ticking certain boxes on the forms we use to collect your data or by contacting us as below.
• The right to lodge a complaint with a supervisory authority
  • Further details of this can be found in our Complaints Policy.

To request any of the above rights, please email info@clearandfair.co.uk or use our contact form on the Contact Us page.

8. Consequences of failing to provide your personal data

As your personal data is required for us to assess your loan application, if you fail to provide the requested personal data in your loan application form, your loan application cannot be approved.

9. Cookies

A cookie is a small text file, which often includes a unique identifier that is sent to your computer or mobile phone (referred to here as a "device") browser from a website's computer and is stored on your device's hard drive. There are various types of cookies which perform different functions, such as remembering the information you provide us in your application for credit or recording your browsing habits. The information recorded by the cookie is retrieved on the user's next visit to the site.

Most web browsers will accept cookies, but if you would rather that we did not collect data in this way you can choose to accept all or some or reject cookies in your browser's privacy settings. If you want to control the use of cookies then you can do so by changing your browser settings. Information on deleting or controlling cookies is available at www.AboutCookies.org. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our site.

On our site, cookies record information about your online preferences, remember information about you when you visit our site and compile statistical reports on website activity. Some cookies are used that are essential in order to provide our services to you.

Information supplied by cookies can help us to analyse the profile of our visitors and help us to provide you with a better user experience. Below we have set out the categories of cookies that we use on our website.

10. Strictly necessary cookies

These cookies are essential in order to enable you to move around the website and use its features, similar to using a shopping basket to continue to navigate the site when making a purchase. Without these cookies, services you have asked for, such as applying for a loan using the website, cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the Internet.

11. Performance cookies

These cookies collect information about how our visitors use the website, for instance which pages visitors go to most often, and if they get error messages from any web pages. They also allow us to record and count the number of visitors to the website, all of which enables us to see how visitors use the website in order to improve the way that our website works. These cookies do not collect information that identifies a visitor, as all information these cookies collect is anonymous and is only used to improve how our website works.

12. Functionality cookies

These cookies allow our website to remember choices you make (such as your login details) or to personalise your browsing experience. The information these cookies collect is anonymous. They do not gather any information about you that could be used for advertising or remember where you have been on the Internet.

13. Google Analytics

We also use Google Analytics which is a web analytics service provided by Google, Inc. It allows us to monitor usage of our site and we use the results in order to help us improve our site for users. Google Analytics uses cookies in order to collect this information. The information collected is in an anonymous format and will not identify you as an individual.

14. Disclosure of your information

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If APFIN LTD or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of use or the terms and conditions of your loan agreement and other agreements; or to protect the rights, property, or safety of APFIN LTD, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

15. Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

16. Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to info@clearandfair.co.uk.

Date this privacy policy was last updated: 24 May 2018