PRIVACY POLICY
We take your privacy very seriously. Please read this privacy policy carefully as it contains
important information on who we are and how and why we collect, store, use and share
your Personal Information. It also explains your rights in relation to your Personal
Information and how to contact us or supervisory authorities in the event you have a
complaint.
We collect, use and are responsible for certain Personal Information about you. When we
do so we are subject to data protection laws applicable in the United Kingdom and we are
responsible as ‘controller’ of that Personal Information for the purposes of those laws.
1. Key Terms
It would be helpful to start by explaining some key terms used in this policy:
2. Personal Information we collect about you
The information we collect about you and how we use it may vary depending on the
products and/ or services we can or currently provide to you.
We may collect and use the following Personal Information about you for example:
- your name, address, date of birth, and contact information, including email address and
telephone number;
- your credit or debit card information, information about your bank account and other
banking information;
- your contact with us, such as a note or recording of a call you make to one of our
contact centres, an email or letter sent, or other records of any contact with us;
- your account information, such as dates of payment owed or received, account numbers
or other information related to your account;
- your employment details; and
- information about how you use our website.
We, us, our
Raylo Group Limited, a company registered
in England and Wales with registered
address 5 New Street Square, London,
EC4A 3TW (registered company number
11554120) and our group of companies
Personal Information
Any information relating to an identified or
identifiable individual
This Personal Information is required to inform you about the products and/or services we
can or currently provide to you. Where you fail to provide that Personal Information when
requested, we may not be able to perform the contract we have or are trying to enter into
with you (for example, to provide you with products and/or services). In this case, we may
have to cancel a product or service you have with us but we will notify you if this is the
case at the time.
3. How your personal information is collected
We collect most of this Personal Information directly from you, by telephone, text or email
and/or via our website and apps. However, we may also collect information:
- from publicly accessible sources, e.g. social media websites;
- directly from a third party, e.g.: - sanctions screening providers; - credit reference
agencies; - customer due diligence providers;
- from a third party with your consent, e.g. your bank or building society; and
- from cookies on our website. For more information on our use of cookies, please see our
Cookies Policy published on the legal page of our website.
4. How and why we use your personal information
Under data protection law, we can only use your Personal Information if we have a proper
reason for doing so. In order to use your personal information, we rely on the following
legal bases:
(i) processing is necessary for the performance of the products and/or services we
provide to you;
(ii) processing is necessary for the purposes of the legitimate business interests pursued
by us (including, for example, improving products and/or services that we oer); and
(iii) processing is necessary for compliance with a legal obligation to which we are subject
(including where applicable undertaking customer due diligence checks for Anti-money
Laundering, Fraud and Sanctions purposes);
(iv) processing is necessary for compliance with a legal obligation to perform a specific
task in the public interest (including for example, assisting with detecting and preventing
fraud, tax evasion and financial crime, or to safeguard the interests of vulnerable
customers.
Generally, we do not rely on consent as a legal basis for processing your Personal
Information other than in relation to sending third party direct marketing communications
to you via email or text message. You have the right to withdraw consent to marketing at
any time by contacting us (see ‘How to contact us’ below).
We collect and process your personal information in order to:
- provide products and/or services to you at a price and value that enable you to achieve
your financial objectives;
- update customer records;
- provide you with the understanding and support you require when taking out a Raylo
product;
- prevent unauthorised access and modification to our systems; and
- undertake statistical analysis to help us manage our business e.g. in relation to financial
performance, client base and work type.
5. Who we share your personal information with
We routinely share Personal Information with:
- companies within the Raylo Group Limited group;
- third parties we use to help deliver our products and/or services to you;
- other third parties we use to help us run our business, eg marketing agencies or website
hosts;
- third parties approved by you;
- credit reference agencies; and
- our insurers, brokers and other professional advisers.
We only allow our service providers to handle your Personal Information if we are satisfied
they take appropriate security measures to protect your Personal Information.
We may be obliged to disclose and/or exchange information with law enforcement
agencies and regulatory bodies, or another third party where such disclosure is required to
comply with our legal and regulatory obligations.
We will make information available if it is deemed reasonable for the purposes of
protecting ourselves or our customers against fraud.
We may also need to share some Personal Information with other parties, such as
potential buyers of some or all of our business or during a re-structuring. Usually,
information will be anonymised but this may not always be possible. The recipient of the
information will be bound by confidentiality obligations.
6. Credit Reference Agencies
In order to process your application, we will perform credit and identity checks on you with
one or more credit reference agencies (“CRAs”).
To do this, we will supply your Personal Information to CRAs and they will give us
information about you. This will include information from your credit application and about
your financial situation and financial history. CRAs will supply to us both public (including
the electoral register) and shared credit, financial situation and financial history
information and fraud prevention information.
We will use this information to:
- assess your creditworthiness and whether you can aord to take the product;
- verify the accuracy of the data you have provided to us;
- prevent criminal activity, fraud and money laundering;
- manage your account(s);
- trace and recover debts; and
- ensure any oers provided to you are appropriate to your circumstances.
We will continue to exchange information about you with CRAs while you have a
relationship with us. We will also inform the CRAs about your account and share
appropriate information with them. If you do not pay in full and on time or if you otherwise
breach the agreement that we have with you, CRAs will record this information. This
information may be supplied to other organisations by CRAs.
When CRAs receive a search from us they will place a search footprint on your credit file
that will be seen by other lenders.
If you have a spouse or financial associate, we will link your records together, so you
should make sure you discuss this with them, and share with them this information, before
lodging the application. CRAs will 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.
The identities of the CRAs, their role also as fraud prevention agencies, the data they hold,
the ways in which they use and share personal information, data retention periods and
your data protection rights with the CRAs are explained in more detail at:
Equifax
https://.equifax.co.uk/crain
https://.equifax.co.uk/About-us/Privacy_policy.html
TransUnion
https://.transunion.co.uk/legal/privacy-centre/pc-credit-reference
https://.transunion.co.uk/legal/privacy-centre/pc-bureau
Experian
https://.experian.co.uk/legal/crain/
https://.experian.co.uk/consumer/privacy.html
7. How long your personal information will be kept
We will only retain your Personal Information for as long as necessary to fulfil the purposes
we collected it for, including for the purposes of satisfying any legal, regulatory,
accounting, or reporting requirements.
Any personal data that we have collected and processed about you will be retained in
accordance with the retention periods set out in Raylo’s data retention schedule. To
determine the appropriate retention period for your Personal Information, we consider the
amount, nature, and sensitivity of the Personal Information, the potential risk of harm from
unauthorised use or disclosure of your Personal Information, the purposes for which we
process your Personal Information and whether we can achieve those purposes through
other means, and the applicable legal and regulatory requirements.
When it is no longer necessary to retain your Personal Information, we will anonymise it
and either delete it, or put it beyond use where it is not technically possible to delete it.
Even if you don’t sign up with Raylo, we will continue to hold personal information about
you to enable us to comply with our legal and regulatory obligations, and to assist us in
the prevention and detection of fraud.
8. Transferring your personal information out of the UK
We may transfer Personal Information that we collect from you to third party data
processors, vendors or hosting partners acting on our behalf located in countries outside
of the UK, such as the US and European Economic Area (“EEA”), or to other entities in our
group of companies in connection with the purposes set out above. Where this is the
case, Raylo will put in place adequate safeguards (by way of standard contractual clauses)
in order to protect your personal data in accordance with the applicable data protection
legislation.
If you would like further information please contact us (see ‘How to contact us’ below).
9. Your rights
You have the following rights, which you can exercise free of charge:
For further information on each of those rights, including the circumstances in which they
apply, please contact us or see the Guidance from the UK Information Commissioner’s
Oce (ICO) on individuals’ rights under the General Data Protection Regulation.
Access
The right to be provided with a copy of your
Personal Information (the right of access).
Rectification
The right to require us to correct any
mistakes in your Personal Information.
Erasure
The right to require us to delete your
Personal Information – in certain situations.
For legal reasons we are not always able to
do so. There may be times when we
continue to use your personal data when we
say it’s in our ‘legitimate interest’
Restriction of processing
The right to require us to restrict processing
of your Personal Information – in certain
circumstances, e.g. if you contest the
accuracy of the data.
Data portability
The right to receive the Personal
Information you provided to us, in a
structured, commonly used and machine-
readable format and/or transmit that data
to a third party – in certain situations.
To object
The right to object: – at any time to your
Personal Information being processed for
direct marketing (including profiling); or – in
certain other situations to our continued
processing of your Personal Information, e.g.
processing carried out for the purpose of
our legitimate interests.
Not to be subject to automated individual
decision-making
The right not to be subject to a decision
based solely on automated processing
(including profiling) that produces legal
effects concerning you or similarly
significantly affects you.
Withdraw consent
The right to withdraw your consent to us
processing your Personal Information at any
time if our processing is based on your
consent.
If you would like to exercise any of those rights, please:
- email, call or write to us – see below: ‘How to contact us’; and
- let us have enough information to identify you (eg your full name, address and customer
or matter reference number);
- let us have proof of your identity and address (a copy of your driving licence or passport
and a recent utility or credit card bill); and
- let us know what right you want to exercise and the information to which your request
relates.
10. Keeping your personal information secure
We have appropriate security measures in place to prevent Personal Information from
being accidentally lost, destroyed, used or accessed unlawfully. These measures are
reviewed on an ongoing basis.
We make every eort to ensure your Personal Information is protected and have robust
procedures in place to deal with any data breach.
We cannot accept responsibility for any unauthorised access or loss of personal
information that is beyond our control.
We will never ask you for personal information or account information by an unsolicited
means of communication. If you are in any doubt, please use the online chat function on
the Raylo website.
11. Right to complain
We hope that we can resolve any query or concern you may raise about how we use your
information. Please email us at complaints@raylo.com and we will endeavour to resolve the
compliant promptly.
If you are still not satisfied, you also have the right to lodge a complaint with the UK
Supervisory Authority, Information Commissioners Oce (ICO) who may be contact at
https://ico.org.uk/concerns or telephone: 0303 123 1133. For more information, please
visit their website, .ico.org.uk.
12. Changes to this Privacy Policy
We may update this policy for example, where a change to the regulation requires us to do
so. Whenever we make a change, we will post this on our website and let you know if there
is a material change.
We encourage you to check our website from time to time to keep informed of any
changes. The privacy policy and cookies policy were last updated July 2023.
