We have developed this policy 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 is your data controller and it is registered under the data protection laws in the United Kingdom (Registration Number: Z1684084). Our contact details are at the end of this policy.
Where required, we will also ask you to confirm and accept conditions and terms 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).
What personal information do we collect about you, and when do we collect it?
We collect information about your use of our website and services (such as the amount of time you spend on our website), which we use to optimise our services and your experience with us.
- We may ask you from time to time about what use you make of the services we provide and what other services you would like us to provide in the future.
We collect information from visitors to our website to help us to make improvements to our website and to the services we make available. We know, for instance, how many visitors there are to our website, when they visited, for how long and to which areas of our website they visited.
What personal information do we collect about you from other companies and organisations?
We collect personal information about you from credit reference agencies and fraud prevention agencies (further details below). In addition, we may receive personal information about you from other companies and organisations such as brokers and affiliates (including for marketing purposes) provided they have appropriate consents to permit us to use it subject to applicable data protection laws. We rely on these third parties to obtain your consent for us to use this information.
For what purposes do we use your personal information?
We may use your personal information in the following ways:
- To communicate with you to provide you with information about the products and services that you request from us;
- To perform any contract we have with you (in particular, the loan agreement);
- For direct marketing purposes if we have your consent to do so (further details below);
- To review, analyse and evaluate your use of our products and services in order to develop and improve the quality of our offerings. We may do this through the use of market research surveys, or such other methods as may be appropriate (further details below);
- To notify you about changes to our website, our services or our products;
- To ensure that content from our website is presented in the most effective manner for you and for your computer or other device;
- As part of our efforts to keep our website safe and secure;
- To ensure our records are accurate and up to date;
- To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To administer our legitimate internal management analysis, audit, forecasts and business planning and transactions;
- To help prevent fraud and reduce credit risk (further details below);
- To establish, defend or exercise our legal rights;
- To comply with our legal, regulatory and internal governance obligations; and
- For monitoring and recording of telephone calls and email communications where necessary for compliance with regulatory rules or self-regulatory practices or procedures relevant to our business, to prevent or detect crime, for quality, training and security purposes (further details below).
This is not a definitive list, but is intended as a fair reflection of the uses made at the current time.
We may use your personal information to ensure we are providing you with a relevant and useful online experience. In order for Morses Club PLC to continually improve and enhance its customer service, we may from time to time use your personal information provided for quality and training purposes.
Market research and surveys
We may use your personal information for statistical purposes, surveys and research purposes in order to consider how we can improve our products, services and performance. In these cases, steps will be taken with a view to ensuring that your privacy rights are not inappropriately undermined, this may include turning personal information into anonymous data so that a person cannot be identified from it.
Credit checking and account management
- If you apply for a loan we will use credit scoring and other automated systems to assess your application and verify your identity. This is necessary for compliance with our legal and regulatory obligations and for our legitimate commercial interests to assess your creditworthiness and the affordability of your loan;
- We will search 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 may 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;
- We and those other companies may use these records and other information to make credit decisions about you. The CRA records may also be used to make credit decisions about your current spouse or partner or any other individual identified that has been financially linked or associated with you. If you tell us that you have a personal relationship with another person that creates a joint financial unit in a similar way to a married couple (for example if you have been living at the same address at the same time) we may: 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 about this (details are included below);
- We will provide information about this agreement and your repayment performance to all of the CRAs and their details are provided under the How to find out more section (below). 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;
- We will also check your details with fraud prevention agencies (“FPAs”) as this is necessary for compliance with our legal and regulatory obligations and for our legitimate commercial interests to verify your identity and guard against fraudulent applications and crime. Should you provide false or inaccurate information and we suspect fraud we will record this and report it to the relevant FPAs. We and other organisations may use these records to prevent fraud and money laundering, or otherwise assess these records in the future, and this may impact your ability to obtain future financial and other services;
- The information about credit check searches above is condensed. You can contact us (see below) if you want to receive full details of how your personal information may be used for credit check purposes.
If you call us to discuss your loan account(s) we will carry out checks to verify your identity. We do this to help protect you from identity theft and fraud, and also to prevent and detect crime and money laundering.
How to find out more
You can contact the CRAs currently operating in the UK; the information they hold may not be the same so it is worth contacting them all. They will charge you a small statutory fee.
- Callcredit , Consumer Services, P O Box 491, Leeds, LS3 1WZ or call 0330 024 7574 or visit website www.callcredit.co.uk
- Equifax Ltd, Customer Service Centre, P O Box 10036, Leicester, LE3 4FS or call 0800 014 2955 or visit www.equifax.co.uk
- Experian, Consumer Support Centre, P O Box 9000, Nottingham, NG80 7WF or call 0344 481 0800 or visit www.experian.co.uk
Monitoring of communications
Where permitted by data protection laws and other applicable laws, we may monitor and record our communications with you, including e-mails and phone conversations. Information which we collect may then be used for training purposes, quality assurance, to record details about the products and services you order from us (i.e. to evidence formation of a contract, as relevant), and in order to meet our legal and regulatory obligations.
Do we share your personal information with anyone else?
We will share your personal information with credit reference and fraud prevention agencies (as mentioned above). In addition, as a normal part of our business we may share your details with other carefully selected partner companies to help provide you with your loan. To enable them to do this, we may need to share your personal information with them. When we do so, these companies are required to act in accordance with the instructions we give them and to keep the information secure.
We may share your personal information to disclose information about you with our nominated Market Research Company in order to carry out Market Research.
In addition we may disclose your personal details to our auditors, solicitors and other professional advisors, and who have agreed to treat your personal details as confidential.
We may provide information, in response to properly made requests, for the purposes of the prevention and detection of crime, and the apprehension or prosecution of offenders. We may also provide information for the purpose of safeguarding national security. In either case we do so in accordance with data protection legislation. We also provide information where we are required to do so for compliance with applicable regulatory, governmental, law enforcement and judicial organisations.
If there is a change (or prospective change) in the ownership of Morses Club PLC or any of its assets, we may disclose personal information to the new (or prospective) owner. If we decide to restructure our business, if we, or any of our assets are acquired or a third party invests in our business, they will become a data controller of your personal information. This means we will share your personal information with these types of third parties and they will be responsible for it, including for treating it appropriately, under the data protection legislation.
We may also share your personal information with other third parties, including those who conduct any services on our behalf which involve the processing of your personal information or who help us to manage aspects of our business, such as IT providers, debt collection agents, tracing agents, advisers and auditors; in addition, Morses Club PLC and other companies in the same group as us who provide services or assistance to us in relation to our business. We take steps to ensure these third parties handle your personal information securely and in accordance with applicable data protection legislation. In particular, if your loan account with us falls into arrears we may pass your details to debt collection agencies and they will use it to make contact with you (whether in person, by post, email or telephone) in order to recover the sums owed.
Transfers outside the European Economic Area
Your personal information may be transferred to countries or territories outside of the European Economic Area. This may happen when we share your personal data with the third parties mentioned above, including those who conduct any services on our behalf which involve the processing of your personal information or who help us to manage aspects of our business, such as IT providers, or who help us with the operation of our website. The recipients may be in countries or territories which have not been assessed as providing adequate protection for personal information. This means that in these countries or territories there may not be the same level of protection for personal information as is relevant in your own country. Steps will be taken with a view to putting in place adequate safeguards for personal information by us prior to any such transfer, as relevant.
Data anonymisation and use of aggregated information
We may convert your personal information into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from that data. We may use this aggregated data to conduct market research and analysis, including to produce statistical research and reports. For example, we may produce reports on which of our products and services attract the fewest or the highest number of enquiries from visitors to our website. We may share aggregated data in several ways, including for the same reasons as we might share personal information (see above).
For how long does Morses Club keep personal information?
The time period for which we keep information varies according to what the information is used for. We comply with all legal requirements to keep data for a minimum period. Unless there is a specific legal requirement for us to keep the information, we will retain it for no longer than is necessary for the purposes for which the data was first collected or for which it is to be further processed.
How can I find out what personal information Morses Club holds about me?
Data protection legislation means that you have certain rights including the right to access or obtain copies of the personal information we hold about you, to clarify inaccurate information and in respect of automated decision making (as relevant). Your right to access or obtain copies of your personal information may extend to (but is not limited to) some or all of the following items to the extent these amount to or contain your personal information:
- 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
- (Morses Club does record some calls for Quality and Training purposes, however, not all calls are recorded. If you want a call recording it is essential that you provide the information requested below, otherwise we will not be able to proceed with your request).
If you would like us to provide copies, you must put your request in writing, enclosing a cheque for £10 made payable to Morses Club PLC and send to Morses Club, Customer Services Team, Kingston House, Centre 27 Business Park, Woodhead Road, Birstall, Batley, WF17 9TD. We are entitled to charge a small fee for dealing with these requests (£10). Cheques should be made payable to Morse Club PLC. We reserve the right to request confirmation of your identity before we process any such request.
You can exercise your other rights by contacting us in the ways described above or by contacting our Customer Services Team)
How can I change the personal information Morses Club holds about me?
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), please contact us and we will make the necessary amendments. Our contact details for this purpose are set out in our Contact Us page.
How can I manage Morses Club’s contact with me for marketing purposes?
If you have provided your consent 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. We may contact you for this marketing purpose by post, SMS, telephone or email.
To change your marketing preferences, you can contact us. 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 unsubscribe.
How do we protect the security of your personal information?
We are serious about guarding the security of your personal information and the details of any transactions or applications made. We take appropriate technical and organisational measures to protect against unauthorised or unlawful processing of your personal information and against accidental loss or destruction of, or damage to, your personal information.
Our contact details
Our contact details are set out in our Contact Us page.
Last updated: 10/04/2017