Fair Information Practices
What personal information do we collect from the people that visit our website?
When creating an application for credit or registering on our site, as appropriate, you may be asked to enter your name, email address, mailing address, phone number, credit card information or other details to help you with your experience, and to help us evaluate your affordability.
When do we collect information?
We collect information from you when you register on our site, fill out a form or enter information on our site.
How do we use your information?
We may use the information we collect from you when you register, make a application for credit, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:
• To improve our website in order to better serve you.
• To allow us to better service you in responding to your customer service requests.
• To quickly process your transactions.
• To send periodic emails regarding your order or other products and services.
How do we protect visitor information?
Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.
We use regular Malware Scanning.
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when a user places an order enters, submits, or accesses their information to maintain the safety of your personal information.
All transactions are processed through a gateway provider and are not stored or processed on our servers.
Do we use 'cookies'?
• Help remember and process applications.
• Understand and save user's preferences for future visits.
• Keep track of advertisements.
• Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third party services that track this information on our behalf.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer) settings. Each browser is a little different, so look at your browser's Help menu to learn the correct way to modify your cookies.
If users disable cookies in their browser:
If you disable cookies off, some features will be disabled It will turn off some of the features that make your site experience more efficient and some of our services will not function properly.
You can not login without cookies disabled, and you should have cookies enabled when creating a new application for credit.
Third Party Disclosure
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide you with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others' rights, property, or safety.
However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
Third party links
We do not include or offer third party products or services on our website.
Google's advertising requirements can be summed up by Google's Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en
We use Google AdSense Advertising on our website.
We have implemented the following:
• Demographics and Interests Reporting
We along with third-party vendors, such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions, and other ad service functions as they relate to our website.
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising initiative opt out page or permanently using the Google Analytics Opt Out Browser add on.
California Online Privacy Protection Act
According to CalOPPA we agree to the following:
Users can visit our site anonymously
Users are able to change their personal information:
• By emailing us
• By calling us
• By logging in to their account
How does our site handle do not track signals?
We honor do not track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.
Does our site allow third party behavioral tracking?
It's also important to note that we allow third party behavioral tracking
COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under 13, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation's consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online.
We do not specifically market to children under 13.
Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify the users via email
• Within 7 business days
We will notify the users via in site notification
• Within 7 business days
We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.
CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
• Send information, respond to inquiries, and/or other requests or questions.
• Process orders and to send information and updates pertaining to orders
• We may also send you additional information related to your product and/or service.
• Market to our mailing list or continue to send emails to our clients after the original transaction has occurred
To be in accordance with CANSPAM we agree to the following:
• NOT use false, or misleading subjects or email addresses
• Identify the message as an advertisement in some reasonable way
• Include the physical address of our business or site headquarters
• Monitor third party email marketing services for compliance, if one is used.
• Honor opt-out/unsubscribe requests quickly
• Allow users to unsubscribe by using the link at the bottom of each email
If at any time you would like to unsubscribe from receiving future emails, you can email us at
• Follow the instructions at the bottom of each email.
and we will promptly remove you from ALL
You are not required to provide us with viewing access to your bank account transaction information (Transaction History) or internet banking access details. You may still be allowed to apply for a loan with us if you do not provide us with this information. However, if you do it will help us make an informed decision about whether we can lend to you.
If you agree that we may access your Transaction History the following provisions shall apply.
Provide Accurate Information. You, agree to provide true, accurate, current and complete information about yourself and your bank accounts (with us or third parties) and you agree to not misrepresent your identity or your account information. You agree to keep your bank account information up-to-date, accurate and complete.
Purposes. We will access your Transaction History using the services of a credit reference agency called Perfect Data Solutions Limited (PDS). We will use your Transaction History to assess your creditworthiness and whether the loan you seek is affordable.
Neither we nor PDS will store or have access to your internet banking credentials, PIN codes or passwords. That information is encrypted in transit and stored by a third party service provider upon their servers in a secure environment outside the EEA.
Third Party Accounts. By agreeing to allow us viewing access to your Transaction History, you authorise PDS and PDS's service providers to access third party sites designated by you, on your behalf, to retrieve information requested by us, and to register to view bank statements over a period of up to 90 days. You agree that PDS and PDS's service providers may, and are instructed by you as your agent and nominated representative, with full power of substitution and re-substitution, for you and in your name, place and stead, in any and all capacities, to access third party internet sites, servers or documents, retrieve information, and use your information, all as described above, with the full power and authority to do and perform each and every act and thing requisite and necessary to be done in connection with such activities, as fully to all intents and purposes as you might or could do in person. This will include the following purposes: copying Transaction History over a 90 day period and storing the copied Transaction History on our servers.
You agree that the Transaction History shall also be used by PDS for credit reference agency purposes and may be taken into account when producing your individual credit score which may be shared with other organisations as part of your credit record.
You acknowledge and agree that when we, PDS or PDS's service providers access and retrieve information and Transaction History from third party sites, this is undertaken as your agent, and not the agent on behalf of any third party (including the bank account provider). You should be aware that third party account providers shall be entitled to rely on this authorisation and agency granted by you. You should also be aware that this service is not endorsed or sponsored by any third party bank account providers. We would recommend that you refer to the terms and conditions of your internet banking provider if you would like more information.
You understand that allowing us to review your Transaction History is at your sole risk.
We are only able to review your Transaction History on an "as is" and "as available basis" as it is made available to us by service providers. It may not be available to us from time to time.
We cannot guarantee that allowing us to review your Transaction History will guarantee the success of your loan application or the rate at which the loan is available.
Why do you ask for my internet-banking details?
Who sees my internet banking log-in details?
No person can access your internet banking details. When you enter your banking credentials on our website they are securely transmitted. The encrypted details are then passed by our credit reference agency, Perfect Data Solutions Limited and associated service providers. They are stored in a highly secure data centre which has a single use, which is to generate a read-only data-feed which we will use to assess the affordability of the loan.
What happens to my internet banking details after input them on your website?
What happens to the bank statements you obtain?
They will be used to make lending decisions about you and stored by us as long as necessary to assist us in managing your account or underwriting loan to you. It will be stored by Perfect Data Solutions Limited, which is a credit reference agency, as part of your credit record. This means that anyone who accesses your credit record in future will be provided with a credit score which is based on all the information held about you including your banking history.
What will my bank say about me inputting my log-in details into your website?
TWe would recommend that you review the Terms and Conditions of your internet banking provider. Before you decide to submit your banking credentials, we would stress that security is of paramount importance, we would especially mention that:
- Your data is encrypted in transit;
- We do not have any functionality over your bank account; and
- We only have access to a read only service.
Please read the following information very carefully:
As a responsible lender, SOCIAL MONEY LIMITED has a legal obligation to take steps to ensure that our customers are creditworthy.
We use a variety of methods to try to make sure that we do not lend money to people who are in financial difficulty. One of these is to carry out a credit reference check. In order to do this, we shall pass the personal data that you provide to us in your loan application to a credit reference agency (CRA) called Perfect Data Solutions Limited which trades as Lending Metrics. Lending Metrics provide us with data about a customer's credit history and borrowing habits. You can contact Lending Metrics at Lancaster Court, 8 Barnes Wallis Road, Fareham, Hampshire, PO15 5TU in writing to request the information that they hold about you (please note, a small statutory fee may be payable).
Important - Your Personal Information
Credit decisions and also the prevention of fraud and money laundering
We may use credit reference and fraud prevention agencies to help us make decisions. What we do and how both we and credit reference and fraud prevention agencies will use your information is detailed in the section called:
A condensed guide to the use of your personal information by ourselves and at Credit Reference and Fraud Prevention Agencies.
By confirming your agreement to proceed you are accepting that we may each use your information in this way.
A condensed guide to the use of your personal information by ourselves and at Credit Reference and Fraud Prevention Agencies
When you apply to us to open an account, this organisation will check the following records about you and others (see 2 below)
- Our own database;
- Those at credit reference agencies (CRAs). When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders. They supply to us both public (including the electoral register) and shared credit and fraud prevention information.
- Those at fraud prevention agencies (FPAs).
We will make checks such as; assessing this application for credit and verifying identities to prevent and detect crime and money laundering. We may also make periodic searches at CRAs and FPAs to manage your account with us.
If you are making a joint application or tell us that you have a spouse or financial associate, we will link your records together so you must be sure that you have their agreement to disclose information about them. CRAs also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.
Information on applications will be sent to CRAs and will be recorded by them. Where you borrow from us, we will give details of your accounts and how you manage it/them to CRAs. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs and FPAs to perform similar checks and to trace your whereabouts and recover debts that you owe. Records remain on file for 6 years after they are closed, whether settled by you or defaulted.
If you give us false or inaccurate information and we suspect or identify fraud we will record this and may also pass this information to FPAs and other organisations involved in crime and fraud prevention.
If you have borrowed from us and do not make payments that you owe us, we will trace your whereabouts and recover debts.
Your data may also be used for other purposes for which you give your specific permission or, in very limited circumstances, when required by law or where permitted under the terms of the Data Protection Act 1998.
How to find out more
You can get in touch with us for any specific information using our contact details above.
You can contact Lending Metrics at Lancaster Court, 8 Barnes Wallis Road, Fareham, Hampshire, PO15 5TU in writing to request the information that they hold about you (please note, a small statutory fee may be payable).
Last Edited on 10.05.18