Supacompare.com Privacy notice

At Supacompare we take the security of your data very seriously and do all that we can to ensure that we conform to the laws and best practice of the industry. The following Privacy Policy, (alongside the Terms and Conditions, Cookie Policy, and any other referred to documents and polices) explains how MediaBlanket Ltd will collect and use the information that we may collect and your rights to view or amend it.

Since the 25th May 2018 you have revised rights under the new EU General Data Protection Regulation (GDPR).

Further information on the above is available from the 'Information Commissioner's Office'

1. Introduction

At Supacompare we value your privacy. We want to be accountable and fair to you and transparent about how we collect and use your personal data.

This privacy notice tells you what to expect when we collect and use personal data about you.

You should also read our Terms and Conditions and Cookie Policy carefully before you decide to use our services.

Any changes we make to this privacy notice will be posted on this page, so please check back frequently.

This privacy notice applies only to the personal data that we collect in relation to our services. Our website may contain links to and from third party websites. For example, we may link to and from the websites of lenders, other credit brokers, credit reference agencies, our partners, advertisers or affiliates. We can’t be responsible for personal data that these third parties collect, store and use through their website without our involvement. You should always read the privacy notice of each website you visit carefully and before you submit any personal data to them.

If you would like further information or require any clarification on anything which is detailed within our Privacy Policy, please email us at hello@supacompare.com or call us on 0161 711 0415.

If you have any queries regarding our website please be patient. COVID 19 is causing staffing number fluctuations so a response may take slightly longer

2. Who we are

Supacompare.com is a trading style of MediaBlanket Ltd, Registered in the UK 07949139. Registered address: MediaBlanket Ltd, The Old Bank, 247 Chapel Street, Salford, M3 5EP. Registered with the Information Commissioner's Office Z3334636. Authorised & regulated by the Financial Conduct Authority under Firm Reference No 723605.

As we will be providing a service to You, We will therefore have no obligation to any other party, only you. Please also be aware that if a third party uses Our services on behalf of You, Our obligation will still be with You being Our Customer. Furthermore, the Terms and Conditions will also relate to You, Our Customer, and not with any other third parties.

3. What data we collect about you

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you. In this privacy notice we’ve used the following definitions to refer to some of this data:

Account data includes:

the basic information you provide when you sign up to use our services (e.g. first name, last name, date of birth, postcode, address details, residential status, employment status, annual income, phone number, email address and password);

any additional ‘affordability information’ you give us (e.g. marital status, additional household income, monthly rent or mortgage cost, how many people depend on you financially, monthly cost of childcare and dependent support); and

any information you give us about your job (e.g. job title, industry and/or company name).

It’s vital that you keep your account data accurate and up to date, because inaccurate personal data will produce inaccurate results. You can update your information in the "My Details" section of your account, and we sometimes will give you a nudge to do so when you log in. If you’re not sure how to update your information, please contact us –hello@supacompare.com

Credit report data means information about your credit file given to us by TransUnion (see section 7).

Credit score data means information about your credit score given to us by TransUnion (see section 7).

Eligibility data means information about your eligibility for the credit products featured on our website, such as your likelihood of being accepted for a particular credit product and the actual or indicative rates of interest and term of borrowing that will apply. This information is given to us by Experian and the lenders and credit brokers with whom we perform direct eligibility checks (see section 7 for more details).

Energy profile data Supacompare uses:

https://www.loveenergysavings.com/ to power our energy for business platform. This means that when you use the Supacompare.com Business Energy service you will be using our partners services and such you may be contacted by them or their partners in relation to business energy.

Supacompare.com may contact regarding other business finance products if we deem it relevant.

Your energy profile data includes information about:

  • your current energy supplier;
  • the energy tariff you are on;
  • your energy usage;
  • your energy meters (i.e. meter type and meter numbers); and
  • your energy payment method (e.g. pre-pay or otherwise).

If you chose to switch energy with us, your energy profile data will include the current status of your switch (e.g. pending or completed, date of your last switch etc.).

Energy results means information about your potential energy savings and the energy tariffs that are available to you.

Marketing data means your marketing preferences (i.e. whether you have opted in or out of receiving marketing messages from us).

Product application data means data about the outcome of product applications you make as a result of using our services, which is given to us by some lenders, lender’s agents and third party brokers and by our energy comparison and switching service provider. We may use this data to update our ranking algorithm (see section 5 for more details), to check that our service is working normally and to calculate the commission that is due to us.

Technical and behavioural data means details of your visits to the website including the actual pages you visit, IP address (from which we may derive your location) and details of the resources that you access. We also capture information about your computer or device including, where available, your operating system and browser type.

We also collect, use and share aggregated data such as statistical or demographic data. Aggregated data may be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

4. How we collect your data

We use different methods to collect data from and about you, including:

Directly. You may give us your personal data by filling in forms or by corresponding with us. This includes personal data you provide when you:

sign up for a Supacompare.com account;

use our service to compare particular products;

contact us (for example by post, phone, email or via our website or app);

give us feedback; or

enter a competition, promotion or survey.

Credit reference agencies. The credit reference agencies that we work with will give us eligibility data, credit score data and credit report data.

Partners. The partners that we work with such as credit issuers, credit brokers or other service providers (referred to collectively in this privacy notice as “partners”) give us eligibility data and, in some cases, product application data.

Automated technologies or interactions. We’ll automatically collect technical and behavioural data as you interact with our website or app. For example, we use cookies and other similar technologies (e.g. pixels) to tell us which area of the website you have visited and which products you have clicked out on. For more information on how we use Cookies and similar technologies, please read our Cookie Policy.

5. How we use your data

Personalisation

All of our services are personalised to you. This means that we’ll analyse and profile your personal data to tailor the services we provide to you. This includes using the information that you have given us directly, such as account data, and also information that we have obtained through third parties, such as your credit report data, credit score data, eligibility data, energy results and product application data.

We’ll use your personal data to personalise the information and offers that we show you in your account and that we send to you by email.

Supacompare will soft search you while your account is live, to provide you with updates and personalised information and offers. We will soft search your credit file with TransUnion and other credit reference agencies:

  • to calculate and update your credit worthiness
  • to create and update your free credit report, if you have one
  • to match you with offers for which you are likely to be eligible
  • to analyse your financial situation, so that we can find other products and services you may be interested in.
Eligibility checking

Our eligibility checking service works to find you offers. We then sort your offers based on their features and what's best for your credit profile. Although we may be paid commission, this never influences how your offers are ranked.

To do this, we use our own automated technology that assesses your personal data to create a profile of you (including your credit eligibility). We then use this information to search for and find suitable products for your credit profile.

Your eligibility results are based on our unique algorithm, which considers factors such as:

  • your credit profile;
  • your eligibility score;
  • the features of the products; and
  • lender reliability.

Visiting our website or app or clicking out on email offers will prompt Experian and some of the partners that we work directly with to soft search your credit file. Some of these soft searches will leave ‘footprints’ on your credit file.

We may use your credit score data and or credit report data to help us decide which lenders or credit brokers to share your personal data with. For some lenders we will pre-check whether you meet the lender or credit broker’s requirements, before we send your personal data to them. For more information about how we share your personal data with lenders and credit brokers, see section 7.

We’ll use your eligibility data to tailor the other services we provide to you. For example, we will use your eligibility data to tailor the marketing we send you, where you’ve agreed to receive marketing from us. For more information about how we use eligibility data to tailor marketing see section 5.8.2.

5.4. Your credit score and free credit report

When you sign up for a TotallyMoney account, we may use your account data to check whether TransUnion is able to provide you with a free credit report and credit score. If we are going to do this check, we will make it clear to you in the sign up terms that are shown to you before you create your account.

You will need to successfully pass an authentication process before we can show you your credit report and credit score. If you pass, TransUnion will give us your credit report data and credit score data and we will display them in your account.

We’ll ask TransUnion for your updated credit report data and credit score data every month for as long as you have a live TotallyMoney account. We reserve the right to suspend these monthly searches if your account is inactive for 12 months or more.

We’ll also ask for your credit score data from TransUnion each time that you log into your account, so that we can provide you with an updated credit score.

We’ll use your credit report data and credit score data:

to provide you with your free credit report and credit score; and

to make our service better and more personalised to you, as explained in this privacy notice.

For a summary of the different ways in which we use your credit report data and credit score data see section 6. Some of the credit report and credit score soft searches that we do will leave ‘footprints’ on your credit file. For more information about soft searches and footprints, see section section 5.5.

5.5. Soft searches and ‘footprints’ on your credit report

Some of our services involve soft searching your credit file. A soft search is like a quick peek at your credit file. Soft searches will not harm your credit rating or affect the way lenders see you.

You may see these soft searches as ‘footprints’ on your credit report in either our name or the name of one of the lenders, brokers or credit reference agencies that we work with. Soft searches on your credit file will be given different markings, depending on their purpose, such as:

  • Affordability
  • Anti-Money Laundering
  • Consumer Credit File Request
  • Identity Check
  • Quotation/Preliminary Search

You may see multiple footprints on your credit file because soft searches will be carried out:

  • when you first sign up for our services;
  • when you log in;
  • when you go to the offers section of your account;
  • when you check or refresh your offers (e.g. when you click on ‘view card’ or ‘find loans’);
  • in the background on a monthly basis to refresh your Borrowing Power, credit report and credit score (we reserve the right to suspend these monthly searches if your account is inactive for 12 months or more).

Here are some examples footprints you might see on your credit file as a result of using our services:

  • AA
  • Avant Credit Of Uk Llc (Cval Sr, Sa, Ct)
  • Avant Credit Of Uk Llc (Sr Api)
  • Barclaycard (Sa Cval Tar Cosmos)
  • Barclaycard (Online) Price Comparison (Ar Api)
  • Bamboo Limited (Cval Tac Cr R)
  • Bamboo Limited (Cr Api)
  • Car Finance 247
  • Evolution Funding
  • Hitachi Capital (Uk) Plc – Price Comparison - Hdd
  • Lendable Limited
  • Likely Loans
  • Likely Loans (TotallyMoney.com)
  • Madison Cf Uk LTD T/A 118 118 Money (Cval Sr Tac)
  • Moneybarn
  • MyCarCredit
  • Norton Finance and Mortgages
  • Oakbrook Finance
  • Paragon
  • Retail Money Market Limited T/A Ratesetter.Com
  • Retail Money Market Limited T/A Ratesetter.Com Sr
  • Shawbrook Bank Limited (Sr, Tac, Cval, Sa, Cosmos)
  • Shawbrook Bank Limited Consumer Lending
  • Totallymoney Limited (Cval)
  • Totallymoney.com with Capital One
  • Vanquis Bank Limited (Sa Sr, Ct, Tac, Cval)
  • Vanquis Hdd Price Comparison (Ar Api)
  • Zopa Limited (Tac)
  • Zopa Ltd.
  • Zuto

If we run a trial with a potential supplier and partner and we need to use real rather than dummy or anonymous data for the test to be effective you may see a footprint relating to that trial on your credit file. See section 7.7 below for more details.

5.6. Credit Karma

Previously, TotallyMoney helped customers of Credit Karma check their eligibility for and compare credit products. Our software ‘powered’ this service, to provide Credit Karma customers with credit card and/or loan offers. We stopped providing this service on 28 January 2020.

5.7. Know Your Money

If you use Know Your Money to compare credit cards, you will be asked to create an account with TotallyMoney. At this point, you will become a TotallyMoney customer and our standard Terms and Conditions and this privacy notice will apply to your use of our services.

5.8. Keeping in touch

5.8.1. Service messages

We’ll send you a welcome email when you sign up.

We’ll send you monthly emails to tell you the results of your monthly Borrowing Power search.See section 5.2 for more information about Borrowing Power.

If you have a free credit report with us, we’ll send you monthly emails as a reminder that we’ve retrieved your credit report and credit score data from TransUnion.

We may also send you ad hoc service emails from time to time (for example, to contact you about forgotten passwords or to notify you about changes to our services).

Calculating your Borrowing Power and retrieving your credit report and credit score from TransUnion are core elements of our account service. We want to make sure that you remember that we are getting this data about you each month, even if you don’t need to log into your account very often. Therefore, please be aware that you can’t unsubscribe from service messages.If you do not wish to receive service messages, you will need to close your TotallyMoney account, which you can do by logging into your account and going to “My Details".

We’ll keep refreshing your Borrowing Power, credit report and credit score (and sending you monthly service messages about them) until you close your TotallyMoney account or we terminate or suspend your account (e.g. for misuse).We reserve the right to suspend these monthly searches if your account is inactive for 12 months or more.

5.8.2. Marketing

When you sign up for a TotallyMoney account, you can choose not to receive marketing messages. You can also unsubscribe from receiving marketing communications at any time by:

  • updating your preferences from within your TotallyMoney account; or
  • emailing us at help@totallymoney.com; or
  • clicking the unsubscribe link in any marketing email from us.

If you have not opted out of marketing (or if you have otherwise consented to receiving marketing from us, for example when you apply for a Fluid card) we’ll use your personal data to send you tailored offers or information about our products and services that may be of interest to you.For example, we will use your personal data to predict when you may be interested in a new product because a product you currently have is coming to an end.

We may occasionally have arrangements in place with third parties that have a direct relationship with you and they may send information to you about us and our services where they are legally permitted to do so.

5.9. Correspondence, surveys, competitions and prize draws

If you contact us, we’ll keep a record of that correspondence.

From time to time, we may use your personal data to contact you to ask you if you would like to take part in a survey, competition or prize draw. We’ll use any personal data you submit for a survey, competition or prize draw in accordance with this privacy notice and any additional terms and conditions associated with the survey, competition or prize draw.

5.10. Website and app analytics

We use technical and behavioural data:

for system administration;

to measure and analyse traffic to our website or app; and

to enable us to analyse behaviour and trends on the website and app. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.

5.11. To meet legal or regulatory requirements

We and our third-party service providers are required to comply with certain legal and regulatory requirements including:

complying with our regulatory obligations to the Financial Conduct Authority and the Information Commissioner; and

addressing enquiries or complaints from you or from a regulator.

We may process your personal data to comply with those requirements. For example, the Financial Conduct Authority requires us to provide extra support to consumers that are vulnerable. To help us do this, we may add a ‘vulnerable consumer’ flag to your customer service record, if we consider that you meet the Financial Conduct Authority’s criteria for vulnerability.

Occasionally, we may be asked to provide certain information to regulators or law enforcement agencies. We’ll comply with these requests where legally required or permitted.

5.12. Fraud prevention

TotallyMoney and the third parties that we work with (e.g. credit reference agencies, brokers and lenders) will process and share your data for the purposes of fraud prevention.

5.13. Research and development

We’ll use your personal data to help us understand our customers and the market better and to improve our products and services. For example, we may analyse our customers’ account data, credit score data, credit report data, product application data and technical and behavioural data to spot trends or identify new product features that would be helpful to our customers.

5.14. User panels and other customer research

From time to time, we may ask you if you would like to join a TotallyMoney user panel or take part in other customer research. We’ll use any personal data you submit or give us access to in accordance with this privacy notice and any additional privacy notice and terms and conditions associated with the user panel or customer research.

5.15. Energy comparison and switching

We’ll use your address to find out how much you might be able to save by using our energy comparison and switching service. We’ll tell you about this potential saving in your TotallyMoney account or, if you have agreed to receive marketing from us, by email.

If you use our energy comparison and switching service, we’ll pass some of your account data and your energy profile data to our energy comparison and switching service provider, Decision Tech, so that they can:

help us to help you complete your energy profile; and

tell us which energy tariffs are available to you (i.e. your energy results).

If you chose to switch energy supplier through us, we’ll pass some of your account data and your energy profile data to Decision Tech, so that they can help you with your switching application. We’ll show you the status of your energy switch in the energy section of your TotallyMoney account.

If you have any questions about your switch, we’ll use your account data and energy profile data to answer your questions, where we can. If we aren’t able to answer your questions, we may pass your complaint to the Moneysupermarket customer services team (Decision Tech is part of the Moneysupermarket group and their customer services team deals with questions on behalf of Decision Tech). Alternatively, we may ask you to contact the energy supplier that you are switching to directly.

If your application to switch is rejected by the energy supplier you have chosen, Decision Tech may use your email address and your energy profile data to send you a TotallyMoney branded email explaining the reason why you have been rejected and what to do next.

If you have agreed to receive marketing from us, we may send you marketing about energy comparison and switching. We may use your personal data to tailor that marketing. For example, we may send you a reminder when your current energy deal is coming to an end.

6. Our legal bases for processing your personal data

We’ve set out below, the legal bases on which we process your personal data. We’ve also identified what our legitimate interests are, where appropriate.

TABLE

7. How we share your personal data with others

7.1. Sharing your personal data with credit reference agencies (Experian and TransUnion)

A credit reference agency is a company that collects personal information from various sources and provides that personal information for a variety of uses (including to prospective lenders for the purposes of making credit decisions).

We share your personal data with Experian Ltd (“Experian”), who conduct pre-screening searches and eligibility checking on our behalf. Experian uses your personal data:

  • so that they can check your eligibility for the credit products listed on our site; and
  • for fraud prevention purposes.
  • Please read Experian’s terms by clicking here).

We share your personal data with TransUnion International UK Limited (“TransUnion”) to provide the credit report and credit score services. When we check whether TransUnion is able to provide you with a credit report and when we retrieve your credit report data and credit score data from TransUnion, we are making a subject access request under Article 15 of the GDPR to TransUnion, on your behalf.

The way that TransUnion uses your data is set out in the TransUnion privacy notice, which can be found here. TransUnion’s company number is 03961870 and their registered office is One Park Lane, Leeds LS3 1EP. TransUnion International UK Limited is authorised and regulated by the Financial Conduct Authority under registration number 737740. Authorisation can be checked on the FCA Register.

If you apply for a free credit report, TransUnion will ask you for personal data to verify your identity and to authenticate you. TransUnion will ask you knowledge-based questions based on your credit history, that only you should know the answers to. We do not see the information you provide, even though it is provided to TransUnion through a TotallyMoney branded interface. We only see the outcome of the authentication process (e.g. authentication pass/failure). If TransUnion can authenticate you for the credit report service, TransUnion will provide us with a unique ID that we use to request your credit report data and credit score data.

The credit reference agencies will use the information you provide when setting up your TotallyMoney account and while using our services for the purposes of operating as a credit reference agency. This will include using such data for statistical purposes, to assist with identity verification, prevention of fraud / money laundering, tracing and collection of debt, service delivery and process implementation.

7.2. Sharing your personal data with lenders

We share your personal data with a range of lenders:

  • so that they can check your eligibility for their products, including whether you’re an existing customer (this helps us to limit the number of soft searches carried out on you);
  • to pre-populate any lender application form you chose to complete; and
  • for fraud prevention purposes.

We may use your credit score data and/or credit report data to help us decide which lenders to share your personal data with. For example, we may pre-check whether you meet the lender’s requirements, before we send your personal data to them.

If you would like any more information about lenders that we currently work with, please email us –help@totallymoney.com.

We may also share limited details about you with lenders or their agents to verify any commission payments due to us as a result of your application.

If you apply for a lender’s product as a result of using our service, they will provide you with the terms and conditions for that product. They will also carry out their own identification and validation checks (including fraud prevention procedures), affordability and credit application checks in accordance with their own criteria. Any full credit check (also known as a ‘hard search’) carried out by a lender will be visible on your credit file to all lenders in the future. The basis on which a lender or other service provider uses your personal data should be set out in their privacy notice.

7.3. Sharing your personal data with other credit brokers

We share your personal data with other credit brokers that we work with.

Some products may need specialist expertise (e.g. certain types of secured loans, mortgages and car finance). If you tell us that you are interested in those products, we’ll introduce you to a specialist credit broker. Look out for notices on our website and app that tell you when we are going to pass your information to another credit broker, as they may contact you to follow up on your enquiry. If you choose to work with another credit broker, you will then be bound by their terms and privacy policy.

The specialist credit brokers we currently work with are:

TABLE

We share your personal data with other credit brokers:

  • so that they can check your eligibility for credit;
  • to pre-populate any application form you chose to complete; and
  • for fraud prevention purposes.

We may use your credit score data and/or credit report data to help us decide which credit brokers to share your personal data with. For example, we may pre-check whether you meet the credit broker’s requirements, before we send your personal data to them.

We may also share limited details about you with credit brokers or their agents to verify any commission payments due to us as a result of your application.

If you apply for a product as a result of using another credit broker’s services, the credit broker or the lender will provide you with the terms and conditions for that product. They will also carry out their own identification and validation checks (including fraud prevention procedures), affordability and credit application checks in accordance with their own criteria. Any full credit check (also known as a ‘hard search’) carried out by a credit broker or lender will be visible on your credit file to all lenders in the future. The basis on which another credit broker uses your personal data should be set out in their privacy notice.

7.4. Sharing your data for energy comparison and switching

Our energy comparison and switching service is powered by Decision Technologies Limited, a company registered in England & Wales under company number 05341159 with its registered address at First Floor, High Holborn House 52-54 High Holborn London WC1V 6RL (“Decision Tech”).

We share your personal data with Decision Tech so that they can help us help you switch. For example, we share your personal data with Decision Tech:

  • to help you complete your energy profile (for example, we’ll share your address with Decision Tech so that they can look up your meter numbers);
  • to find out what energy tariffs are available to you; and
  • to pre-populate your switching application form.

Decision Tech will share limited details about you with their suppliers so that we can help you switch. For example, Decision Tech share your address with GB Group plc, who provide Decision Tech’s address look-up service.

Decision Tech is part of the MoneySupermarket group of companies. Decision Tech will share limited details about you with MoneySupermarket so that we can help you switch. For example, if your switch is rejected, MoneySupermarket may email you on our behalf to tell you why and what to do next.

For more information about how Decision Tech will use your personal data, please read theirPrivacy Notice.

If you choose to switch energy suppliers, the energy supplier you are switching to will provide you with the terms and conditions for your new energy tariff. The energy supplier will also carry out their own security and credit checks. Any full credit check carried out by an energy supplier will be visible on your credit file to all lenders in the future. The basis on which the energy supplier you are switching to uses your personal data should be set out in their privacy notice.

7.5. Sharing your personal data with marketing service providers and third-party advertising companies

We share a limited amount of your personal data with companies that help us with marketing and advertising, namely:

  • your marketing preference data (i.e. whether or not you have agreed to receive marketing from us);
  • your technical and behavioural data (e.g. cookie and pixel data); and/or
  • your email address (in a protected format).

The marketing and advertising companies with whom we share your personal data include:

service providers who provide platforms and systems that we use to help us serve marketing and advertising (i.e. Facebook and Taboola); and

our television advertising agency, All Response Media, who use cookie data to track the effectiveness of our television advertising (e.g. to spot spikes in traffic to our website when one of our television adverts is shown).

Some of this information is gathered through cookies and other similar technologies on our website and app. For more information about how we use cookies please see our Cookie Policy.

In some cases, these third parties will also use the data that they collect for their own purposes, for example they may aggregate your data with other data they hold and use this to inform advertising related services provided to other clients.

7.5.1. Sharing your personal data with Facebook (in more detail)

We share customer email addresses (in a protected format) and cookie data about customers and recent visitors to our website with Facebook, so that Facebook can help us show our adverts to the right people. For example, we share this data with Facebook so that we can exclude existing customers and people that have visited our website recently from advertising campaigns that are aimed at finding new customers.

We may share your marketing data, information about your visits to our website (i.e. cookie data) and/or your email address (in a protected format) with Facebook:

to prevent you from receiving TotallyMoney targeted adverts on Facebook if you have opted out of TotallyMoney marketing;

to exclude you from advertising campaigns aimed at finding new users, if you already have a TotallyMoney account;

to show TotallyMoney adverts to users who have visited the TotallyMoney website but haven’t yet created a TotallyMoney account;

to show TotallyMoney adverts to existing TotallyMoney customers to encourage them to use the service (for example, when we make improvements to the service, we may advertise these improvements to existing customers);

to create an audience for our advertisements of other Facebook users who have similar characteristics to you based on the information Facebook holds about you (also known as a Lookalike Audience); or

to include you in a “custom audience” that will receive TotallyMoney advertising content on Facebook (a custom audience is essentially a list of people who we think are most likely to be interested in a particular advertisement).

7.5.2. Sharing your personal data with Taboola (in more detail)

We use Taboola to place advertising on our behalf. Taboola will place TotallyMoney adverts on third party publisher sites that host advertising. We share cookie data with Taboola to allow Taboola to show TotallyMoney adverts to users who have visited the TotallyMoney website but haven’t created a TotallyMoney account. We also share cookie data with Taboola to allow them to exclude existing TotallyMoney customers from TotallyMoney advertising campaigns that are aimed at finding new customers.

7.6. Sharing your personal data with group companies

We work with and are an appointed representative of MI Money Limited to provide our services to you. This requires us to share your personal data with MI Money Limited, so that MI Money Limited can meet its regulatory obligations as the regulated principal.

We may also disclose your personal data to any member of the TotallyMoney group, which means our subsidiaries, as well as our ultimate holding company and its subsidiaries. For example, way may share your personal data with group companies:

if another group company is helping us deliver the services;

where we have regulatory reporting requirements that mean we need to share personal data; or

in the event of a corporate restructure.

7.7. Sharing your personal data with other third parties

We may share your personal data with:

the Financial Conduct Authority, the Information Commissioner’s Office or any other legal, regulatory or governmental body that we are required to disclose information to;

our suppliers of technical and support services, insurers, logistic providers, and cloud service providers;

the analytics and search engine providers that assist us in the improvement and optimisation of our website.

We may share your personal data with potential suppliers and partners if want to trial those suppliers and partners to see if they can help us improve our services. For example, we may share your personal data with potential suppliers and partners to test the efficacy of their systems. We’ll only do this where we need to use real rather than dummy or anonymous data for the test to be effective. Some of these trials will involve soft searching your file and may leave footprints on your credit file. For more information on soft searches and footprints, see section 5.5 above.

We may consider corporate transactions such as a merger, acquisition, reorganisation or asset sale. We may share information with third parties in relation to that transaction. If we are acquired in whole or part, customer personal data may be one of the assets transferred.

We may disclose or share your personal data with third parties (e.g. professional advisors or public bodies) if it is necessary to:

enforce or apply our terms of use and other agreements;

protect the rights, property or safety of our staff, customers or other people.

This includes exchanging information with other companies and organisations for the purposes of identity verification and validation, fraud protection and credit risk reduction.

7.8. Transferring your personal data internationally

The data that we collect from you may be transferred to, and stored at, a destination outside of Europe (for these purposes “Europe” means the European Economic Area ("EEA") and the UK if the UK is no longer part of the EEA) in connection with the above purposes. For example:

we use an American email service provider to send our service and marketing emails;

we use an American software provider to supply the software platform we use to manage customer queries;

the credit reference agencies and partners that we work with may also transfer your personal data outside of Europe (for more details, please read their privacy notices).

If we transfer any of your personal data outside of Europe, we’ll take steps necessary to ensure that your data is treated securely and in accordance with this privacy notice and all relevant statutory requirements. This includes using recognised transfer mechanisms that incorporate appropriate safeguards. For example, we use the European Commission approved standard contractual arrangements to transfer personal data, where appropriate. Further details on the steps we take to protect your personal data in these cases is available from us on request by contacting us by email at dpo@totallymoney.com at any time.

8. How we store your personal data

8.1. What we do to keep your personal data safe

All the information that you give us is stored on secure servers. The internet is not a secure medium, but we’ve put in place various security procedures to protect your information. We use firewalls to block unauthorised traffic to the servers. The actual servers are located in a secure location which can only be accessed by authorised personnel. We use industry-standard encryption technology to ensure that all your personal and transactional information is encrypted before transmission to certain lenders or third-party service providers. Our security policies are in place to safeguard your privacy from unauthorised access or improper use. We’ll continue to enhance our security as and when new technology becomes available.

8.2. What you can do to keep your personal data safe

You’re responsible for keeping your TotallyMoney account password confidential. We ask you not to share a password with anyone. From time to time, we or our service providers may communicate with you by email. You should keep your email account secure. Where possible, you should not provide us with any personal data that we’ve not asked for. If you’re unsure whether we need a certain piece of information, please ask us first before sending it to us.

8.3. How long we keep your personal data for

We keep your personal data for no longer than necessary for the purposes for which the personal data is processed. We may retain personal data where we need to for:

  • the purposes of complying with our legal and regulatory responsibilities;
  • responding to legal and regulatory enquiries; and
  • our own required record keeping.

For example, we’ll keep your sign-up data, eligibility data, credit report data, credit score data, marketing data and technical and behavioural data for as long as your account is live. If you close your account, we’ll remove this data from our live systems. We’ll archive a limited amount of personal data (e.g. your address, postcode, date of birth and email address) so that we can:

  • Answer any queries/complaints you may have;
  • Respond to queries or investigations from the Financial Conduct Authority or Financial Ombudsman Service;
  • Respond to legal claims.
  • We’ll keep the archived data for no longer than six years following your account closure.

9. Your legal rights

You have various rights in respect of our use of your personal data, including:

9.1. Your right to be informed

You have the right to be informed about the collection and use of your personal data. This is a key transparency requirement under the General Data Protection Regulation (“GDPR”). We must provide you with information including:

our purposes for processing your personal data;

our retention periods for that personal data; and

details of who it will be shared with.

This information is set out in the transparency notices on our website and app and in this privacy notice.

9.2. Your right to access

You have the right to access the personal data that we hold that relates to you. This is commonly referred to as a subject access request or “SAR”. You can make a SAR and view the personal data TotallyMoney holds on you. Please note that the personal data won’t include:

Information relating to another person (e.g. a fraudster) who has opened an account in your name, where we’ve good reason to believe that the personal data doesn’t relate to you (e.g. that person’s IP address);

your credit report and credit score (you will need to contact TransUnion for this information, because we don’t have direct access to it).

9.3. Your right to rectification

This right lets you correct or change any personal data we hold on you that’s wrong or out of date. You can change any of your account information, except your date of birth, by visiting ‘Edit My Details’ in your account. If you would like to change your date of birth, or you’re having problems editing your details, please contact us at help@totallymoney.com. Please note that we can’t correct information on your credit report. You can challenge incorrect information on your credit report using the “raise a dispute” function in your account. This will allow you to raise the dispute directly with TransUnion, who provide the credit report data.

9.4. Your right to erasure

Your right to erasure (or ‘the right to be forgotten’) is a right to ask for your personal data to be erased. We can do this — no problem — but it means we’ll close your account. Without certain personal data we can’t deliver our services. And if we can’t deliver our services, we become pretty useless to you. Once you’ve requested your right to erasure we’ll comply, but we can’t immediately delete everything. Some information associated to your TotallyMoney account must be kept for a limited period, for legal and regulatory purposes (see section 8 for more details).

9.5. Your right to restrict processing

You have the right to request that we restrict or suppress the processing of your personal data. This is not an absolute right and only applies in certain circumstances, including where:

you contest the accuracy of your personal data and we are verifying the accuracy of the data;

the data has been unlawfully processed and you oppose erasure and request restriction instead;

we no longer need the personal data, but you need us to keep it in order to establish, exercise or defend a legal claim; or

you have objected to us processing your data under Article 21(1) of GDPR (e.g. an objection to processing on the grounds of legitimate interest), and we are considering whether our legitimate grounds to process your data override your rights and interests.

9.6. Your right to data portability

The right to portability lets customers transfer data easily from one system to another. It’s safe and secure and doesn’t impact the data’s credibility. You can request a copy of the data that you have provided to TotallyMoney in a re-usable format. This right relates to personal data you have provided to us where our legal basis for processing is performance of a contract or consent (e.g. sign-up data).

9.7. Your right to object

You have the right to object to our processing of your personal data. This effectively allows you to ask us to stop processing your personal data. The right to object only applies in certain circumstances. Whether it applies depends on our purpose for processing and our lawful basis for processing.

You have the absolute right to object to the processing of your personal data for direct marketing purposes. If you exercise this right, we’ll stop using your personal data for this purpose.

You can also ask us to consider any valid objections which you have to our use of your personal data where we process your personal data based on our, or another person's, legitimate interest. This is not an absolute right, and we can continue processing your personal data if:

we can demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms; or

the processing is for the establishment, exercise or defence of legal claims.

9.8. Your right to withdraw consent

If we rely on consent to use your personal data in a particular way, but you later change your mind, you may withdraw your consent by contacting us at help@totallymoney and we’ll stop doing so. Details of where we rely on consent can be found in the section 6 above.

9.9. How to exercise your rights

To exercise the rights outlined above in respect of the personal data processed by us as a controller contact us or email us at help@totallymoney.com. We may need further information to verify your identity before we can respond to your request. We’ll consider all requests and provide our response within a reasonable period (and in any event any period required by applicable law). Certain personal data may be exempt from such requests in certain circumstances. If an exception applies, we’ll tell you this when we respond to your request.

9.10. Your right to complain

If you have any complaints about our collection, use or storage of your personal data please contact us at help@totallymoney. We’ll investigate and attempt to resolve your complaint. You may also make a complaint to the UK Information Commissioner (www.ico.org.uk). Alternatively, you may seek a remedy through local courts if you believe your rights have been breached.

If your complaint relates to the data that TransUnion holds and we can’t resolve your complaint, we may refer it to TransUnion.

10. How to contact us

If you have any questions about this privacy notice or our use of your personal data, please contact us or email us at help@totallymoney.