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We have developed this notice because we want you to feel confident about the privacy and security of your personal information and because we would like to explain how we will use and process it. Morses Club PLC (“we”, “us”, “our”) is your controller and abides by applicable data protection laws.

When we refer to "personal information" in this Privacy Notice, we mean information which identifies you as an individual (whether on its own or in connection with other information that we hold about you). For example, your name, address, email address, phone numbers, and perhaps some less obvious details like a list of payments you already make. We hold, use and share data about you in your capacity as a consumer for the purposes mentioned in this Privacy Notice.

We have a Data Protection Officer who can be contacted by e-mail at [email protected], by telephone on 0330 0450749 or by post at:

Data Protection Officer
Building 1, The Phoenix Centre
1 Colliers Way
Nottingham
NG8 6AT

Please read this Privacy Notice carefully. It explains clearly how we will use your personal information collected when you use our website and/or apply for, and are accepted for, a loan and as part of the other services that might be included as part of this process.

This Privacy Notice applies to how Morses Club deals with your personal information which is collected through our www.morsesclub.com website (our “website”), when you apply for a loan product or when we are otherwise in contact with you (for instance when you call us or email us). It does not apply to any other company or to any other company's websites even if you access them through Morses Club. If you disclose your personal information to other companies your information will be dealt with according to their own privacy policies and practices.

In the terms and conditions of your loan agreement you will see additional information about data protection, credit checks and how we use and share your personal information. For the avoidance of doubt, this Privacy Notice is our primary Privacy Notice and any additional items covered in your loan agreement should be considered as supplemental.

You may also be required to enter into terms and conditions associated with each of our services you use (for instance, we will ask you to sign terms and conditions which are in a loan agreement if your application for a loan is successful).

We collect the following personal information from you:

* The processing of these categories of personal data is mandatory in order for us to assess your eligibility for a loan and to enable us to administer the loan during its term. A failure to provide this information may result in us being unable to offer you our products and services.

Our website uses cookies to distinguish you from other users of our website. Please read our Cookie Policy for more information about which Cookies we use. Third parties will use cookies and similar technologies to collect or receive information from this website and elsewhere on the internet. They will use this information to provide measurement services and target ads. Users can opt-out of the collection and use of information for ad targeting at www.aboutads.info/choices.

We will use your personal information in the following ways:

Where we process personal data relating to whether you have any special needs or are otherwise vulnerable, we will process this only if one of the following reasons apply:

• where you have given explicit consent to the processing of such data;
• for the establishment, exercise or defense of legal claims;
• where the processing is necessary for the purposes of carrying out obligations and exercising specific rights in the field of social security and social protection law;
• where you have manifestly made public that personal data; or
• where the processing is necessary for the substantial public interest of safeguarding the customers economic wellbeing.

If you apply for a loan we will use credit scoring and other automated systems to assess your application, assess your ability to sustainably repay your loan commitment, and verify your identity.

Our automated systems gather information from Credit Reference Agencies (see below for more information) and/or data held by Morses Club PLC about your credit score and credit history. The systems check this information against our bespoke scorecards and credit policy rules to assess the suitability for your application. If you do not meet the minimum eligibility criteria, then your application will be declined. If you exceed the minimum criteria, the systems will use the information to determine the maximum loan value that Morses Club will be able to offer you.

Additionally, the personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found at www.cifas.org.uk/fpn.

A final decision as to whether to accept your loan application and the value that Morses Club may loan to you will be made, by a member of our team, following an affordability assessment (based on your verified salary, details of your non-salary income, details of your regular or one-off expenses, and credit reference agency data to determine your current credit commitments) who will determine your ability to sustainably repay your loan commitment.

You have a right to request that your application is reviewed by a member of our team, to express your point of view on the decisions that we make about you and to contest our decisions.

We will check your records through one or more credit reference agencies (“CRAs”) when considering your application. CRAs supply us with details of your credit history and associated information as well as information from the electoral register which is used to verify your identify and your residence.

When CRAs receive a credit check search request from us, they will always record details of this search and this means they will place a search ‘footprint’ on your credit file. That footprint will be seen by other lenders and persons unrelated to us (i.e. the other customers of the CRAs) if they undertake credit checks on you in the future in connection with their own financial products and services; we will carry out “soft” searches at the CRAs after the full credit check searches if we need additional verification of your identity after receiving the result of the full credit search and if we do this no-one else except you would see that we have made this additional enquiry.

Furthermore, Morses Club may also undertake an administration search. This type of search may be conducted in order to assess a customer’s ongoing suitability/affordability for new products and offers. These searches can only be viewed by Morses Club, the customer and the credit reference agencies.

TransUnion Information Group may copy, store, use and sub-license the Input (including the electronic mail and internet protocol addresses that form part of the Input) to enable the TransUnion Information Group companies to provide services to their clients in which the Input is used to assist with identity verification and prevention of fraud/money laundering only. More information about this is available at the following link:

http://www.transunion.co.uk/legal-information/bureau-privacy-notice

We will provide information about this agreement and your repayment performance to all of the CRAs. We report to these third parties at least once a month, including details of the payments you make, payments that you do not make on time and details on any default against this agreement. Our records will remain on your credit file for 6 years after they are closed, whether settled by you or defaulted by us.

The personal data that we will share with CRAs include your:

• Your full name and initials;
• Your postal and correspondence address(es);
• Your date of birth;
• Your marital status;
• Your contact telephone numbers (daytime and evening);
• Your e-mail address;
• Your National Insurance number;
• Your history of name changes;
• Your postal address history;
• Your Bank Name, Bank Account Number and Sort Code;
• Details of your payment history for loans taken with us.

The CRAs can also share your information with other organisations.

CRAs will provide us with the following information relating to you:

• Your name and aliases;
• Your date of birth;
• Your address and contact details (including address links where it appears you have moved house);
• Your financial details including details of your debts;
• Your court judgments that have been issued against you;
• Your bankruptcies, Individual Voluntary Arrangement (IVAs), debt relief orders and similar events relating to you;
• Fraud prevention indicators;
• "Gone away indicators" (which indicate whether you have left an address, deceased or partially settled your account);
• Search footprints where enquiries have been made about you;
• Your credit scores and ratings;
• Your financial associations to which you are linked;
• Flags and triggers, for example where you may be flagged as subject to fraud, and indicators of the certainty of the information they provide;
• Your insolvency and repayment history;
• Your phone number data
• Politically exposed persons (PEPs) and sanctions data.

We and those other companies will use these records and other information to make credit decisions about you. The CRA records will also be used to make credit decisions about your current spouse, partner or other individual that has been financially linked or associated with you (for example if you have a joint account with them). We will: search, link and/or record information at CRAs about you both; link any individual identified as your financial associate, in our own records; take both your and their information into account in future applications by either or both of you (as relevant), and continue this linking until one of you notifies us that you are no longer linked; links between all such persons will remain on your and their files at the CRAs until such time as you or the other relevant person successfully files for a disassociation with the CRAs. If your circumstances change such that you are no longer a financial unit with another person, you should contact the CRAs directly using the contact details in the “How to find out more about Credit Reference Agencies” section below.

More information about CRAs and how they use personal data is available at the following links:

• For Experian: www.experian.co.uk/crain
• For Equifax: www.equifax.co.uk/crain
• For TransUnion: www.transunion.co.uk/crain

You can contact the CRAs currently operating in the UK; the information they hold will not be the same so it is worth contacting them all.

• TransUnion International UK Limited One Park Lane, LEEDS, LS3 1EP Tel: 0330 024 7574 or email: [email protected]
• Equifax Ltd, Customer Service Centre, PO Box 10036, LEICESTER LE3 4FS Tel: 0333 321 4043 or 0800 014 2955 or email [email protected]
• Experian, PO BOX 9000, NOTTINGHAM, NG80 7WP Tel: 0344 481 0800 or 0800 013 8888
• CreditSafe, Creditsafe Business Solutions Limited, Bryn House, Caerphilly Business Park, Van Road, Caerphilly or visit www.creditsafe.com/gb/

In some instances, your application for a Morses Club PLC loan maybe subject to additional checks in order for a lending decision to be made. If this is the case, you will need to agree to our use of consents.online, a third-party Account Information Service Provider (AISP)for the purpose of them passing some of your financial information to us. Consents.online is an FCA regulated service that lets you grant us permission to view the information that appears on your bank statements through “Open Banking”. This is a paper-free way of you sharing your income and expenditure information with us so that we can thoroughly and fairly assess whether you can afford to take out a loan. It also removes the need for you to send bank statements, pay slips or other income and expenditure-related information to us.

You are not automatically opted into Open Banking and we will only use it in relation to your application if we decide if it is required and you give permission to consents.online. This is what we mean by ‘consent’ throughout this section 9. If you give consent for this, consents.online will share your personal information (further details below) with Morses Club PLC. It is important to understand that ‘giving consent’ is in the context of consent under Open Banking regulations and is not the same thing as ‘giving consent’ in the context of consent under the General Data Protection Regulation (GDPR). The consent you give to consents.online means you are giving your permission to them so that they can share your personal information with Morses Club PLC in accordance with the contract they have with you. When you look at the privacy notice of consents.online you will see that they share your personal information with providers like us based on the GDPR lawful basis of it being necessary to administer the contract which they have with you. In turn, we then use this personal information for our legitimate interest of doing what we describe at the end of the paragraph directly above.

As part of the Open Banking process, we will direct you to consents.online, who will ask you to provide your first and last name, email address and phone number. You will then be asked to select which bank/building society you hold your current account with before being asked for your consent to access the following account information and share it with Morses Club PLC:

• Name of your bank/building society
• Your account name, number and sort code
• Your account balance
• Incoming transactions for the last six months
• Outgoing transactions for the last six months

Once you have given consent to consents.online, a secure, encrypted connection will be made with your bank/building society and you will be asked to authenticate yourself in the same way as you would to access your online banking log in. Your bank/building society will then ask you to confirm that you would like to share your account information with consents.online before this is passed to them, who will then share it with us.

You will only be providing consent to consents.online accessing this information and sharing it with us on a one-off basis and we will be limited to read-only access and cannot make any changes to your bank account. We will not ever share this information with any other third party.

You can withdraw your consent to this service at any time by contacting consents.online by email at [email protected] or telephone on 0800 180 8570. This means withdrawing your permission – this is not the same thing as withdrawing a GDPR consent and we have explained why above. Withdrawing your consent means that consents.online will delete their record of your statement data and we will no longer be able to access it, though we will retain a record that we referred to consents.online in order to make a lending decision regarding your loan.

We will use this information as part of our credit and affordability checking processes, which includes verifying your income and expenditure, in order to decide whether we can offer you a loan. We will notify you of the outcome of this review.

If you do not agree to consents.online supplying us with your bank account information via Open Banking, where we request this, you will not be able to complete your loan application and we will not be able to provide you with a loan.

When consents.online uses your personal information, it will be acting as a controller of that information. It will process your information in its own name as it has the sole mandate for that (which means it takes all decisions in relation to its own use of your personal data and we have no control over its use of your personal data). Please read consents.online’s privacy notice for more information about how it will process your personal data as a data controller. You will be able to view this once we direct you to consents.online’s website towards the end of your application.

In addition, as a normal part of our business we will share your details with:

• our market research provider to enable them to conduct customer satisfaction surveys on our behalf to monitor and improve the quality of our product and service offerings;
• our third party payments provider to enable us to process debit card transactions when you make payments against your loan by debit card;
• our professional legal, accountancy and other advisors and auditors based in the United Kingdom in order to obtain legal, accountancy and other professional advice;
• our IT service providers based in the United Kingdom and India that provide network and storage infrastructure and/or software programs and support to us in connection with the operation of our business;
• Where you have requested that your loan is paid directly to your Bank Account using Faster Payments, our supplier of Faster Payments for the purposes of providing your loan directly into your Bank Account
• debt collection agencies, if your loan account with us falls into arrears, to enable them to make contact with you (whether in person, by post, email or telephone) and recover the sums owed.
• we use live chat software on our website, this is provided by a 3rd party UK based software company.

Where we have received your personal details from a broker or another provider of loan products, we will notify such broker or loan provider whether you are eligible for a loan application with us and whether you have obtained a loan from us.

We will disclose your personal data to third parties if we are under a duty to disclose or share your personal data in order to comply with any laws, regulations or good governance obligations, or in order to enforce or to protect its rights, property or safety, or that of our customers or other persons with whom we have a business relationship. These third parties will include (without limitation) the police, Action Fraud, the National Crime Agency, HMRC, HM Treasury and the Department of Work & Pensions.

In the event that we sell any part(s) of our business and/or assets, we will also disclose your personal data to actual or potential purchasers of parts of its business or assets, and their respective advisers and insurers for the potential purchaser’s legitimate interests of:

• enabling potential purchasers to complete due diligence on, and value, the business and/or assets;
• transferring the personal data in connection with any relevant sale and the transfer of our contractual rights and/or obligations; and
• the use of such personal data by a purchaser for the operation of its business.

We will share your personal data with our:

• IT system developers in India to enable them to support our IT infrastructure. India is not designated by the European Commission as providing an adequate level of protection for personal data. In order to safeguard your personal data in respect of these transfers, we have implemented a data transfer agreement with our supplier which incorporates the European Commission standard contractual clauses for the transfer of personal data to processors established in third countries, under Article 46(2) of the General Data Protection Regulation. You can obtain a copy of this data transfer agreement by contacting us (as set out in the “Our Contact Details” section below);
• Customer communication platform. Data is stored within the EU, but our vendor uses a ‘follow the sun’ support model. Transfer may take place if a representative located in an international location accesses data for support purposes. The international location could be Australia, USA, Belarus or South Africa. The named countries are not designated by the European Commission as providing an adequate level of protection for personal data. In order to safeguard your personal data in respect of these transfers, we have checked that the supplier of the service has data transfer agreement in place which incorporates the European Commission standard contractual clauses for the transfer of personal data to processors established in third countries, under Article 46(2) of the General Data Protection Regulation.

If you take out a loan with us, we will retain your personal data for the period during which your loan remains outstanding and thereafter until the expiry of a period of six years on closed accounts and ten years on live/active accounts.

If you apply for a loan and your application was unsuccessful, your personal data will be held by us for up to 50 days.

If you complete a customer satisfaction survey, your personal data in relation to that survey will be held by us for a period of up to 6 months from the date that you submitted the survey response.

If you raise a complaint or there is a dispute between us, your personal data will be held by us for a period of up to seven years following the resolution of the complaint or dispute.

If you raise a general enquiry with us (which does not involve a complaint or dispute), your personal data in relation to that enquiry will be held by us for a period of up to one month.

We will retain your personal data for longer than the periods specified above if required by law, to defend or exercise legal rights (such as defending legal claims) or to comply with regulatory obligations.

It is important to us that you are in control of your own information. As a result, we offer the following controls:

The Right Of Access. You may request access to or copies of the personal information that we hold about (known as a “Data Subject Access Request”) you as set out in the “How can I find out what personal information Morses Club holds about me?” section below. If you would like to exercise this right, please contact us (as set out in the “Our Contact Details” section below).

The Right To Rectification. You have the right to have inaccurate information about you corrected. For more information, see the “How can I change the personal information Morses Club holds about me?” section below.

The Right To Erasure. You may request that your personal information be deleted where it is no longer necessary for the purposes for which it is being processed and provided there is no other lawful basis for which we may continue to process such personal information. If you would like to exercise this right, please contact us (as set out in the “Our Contact Details” section below).

The Right To Data Portability. Where you have provided us with your personal information that we process using automated means, you may be entitled to a copy of that personal information in a structured, commonly used and machine readable format. If you would like to exercise this right, please contact us (as set out in the “Our Contact Details” section below).

The Right To Object. In some circumstances, you may, on grounds relating to your particular situation, have grounds to object to our processing of your personal information. We will consider any objections to its processing on the particular circumstances relating to each case. If you would like to exercise this right, please contact us (as set out in the “Our Contact Details” section below).

The Right To Restrict Processing. You may also request that we restrict the processing of your personal information to that to which you have consented or for the establishment, exercise or defence of legal claims or the protection of the rights of another person:

• whilst we verify your data as set out in “The Right To Rectification” above;
• pending verification of our legitimate grounds for processing your personal information; or
• if the processing is unlawful or no longer necessary but you wish for us to retain your personal information for the purposes of establishing, exercising or defending legal claims.

If you would like to exercise this right, please contact us (as set out in the “Our Contact Details” section below).

Furthermore, you can also exercise your right via the Information Commissioner, who is the supervisory authority and an independent regulator. Details Below:

Telephone: 0303 123 1113
https://ico.org.uk/make-a-complaint/

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF

Your right to access, as detailed above, or to obtain copies of your personal information may extend to (but is not limited to) some or all of the following items below.

• Copy of your Loan Agreement
• Your loan application details
• Your payment history with us
• Statement of Account
• Customer Notes
• Any charges applied to your account
• Telephone calls recorded for quality and training purposes. (Not all calls are recorded)

We will endeavor to return your details from 1 month of receiving the request.

A Data Subject Access Request is free. However, where a request is manifestly unfounded or excessive, we may require a reasonable administrative fee or refuse to act on the request. This will be based on the true administrative cost and will be discussed with the requester on application.

You can make a Data Subject Access Request or exercise your other rights by contacting us (as set out in the “Our Contact Details” section below).

Please tell us if your personal information, including contact details or address, change at any time so that we can update our records. If some of the information we hold about you is inaccurate (for instance because you have changed your marital status or name, or moved house, or changed your telephone number or email address) or incomplete, please contact us (as set out in the “Our Contact Details” section below). We will take steps to seek to correct or update any information if we are satisfied that the information, we hold is inaccurate or incomplete. In certain circumstances, you may also request that we restrict our processing.

If you are opted-in to receive direct marketing communications, for instance when you submit your name and contact details through our website, or when you apply for a loan, we will use your contact information to communicate with you in relation to products and services which you have confirmed you would like to hear about from us. Depending on the specific permissions you gave, we may contact you by post, SMS, telephone or email.

To change your marketing preferences, you can contact us using our contact details set out in our Contact Us page. We will process your request within a reasonable period of time.

Any marketing communication by email or SMS which are from us will also include details of how you may unsubscribe.

We are serious about guarding the security of your personal information and the details of any transactions or applications made. We use the triage of Confidentiality, Integrity and Availability (CIA) as the keystones to our technical and organisational controls. This helps us protect against unauthorised or unlawful processing, accidental loss or destruction of, or damage to, your personal information.

If you require a printed copy of this Privacy Notice or a copy in another format such as audio or Braille, then please contact us using the contact page.

You can contact us by post at Morses Club, Building 1, The Phoenix Centre, 1 Colliers Way, Nottingham, NG8 6AT, by e-mail at [email protected] by telephone on 0330 045 0719 or using our contact form on our Contact Us page.

Last updated: 30/01/2023