• info@hnwlending.co.uk
  • |
  • 72 Charlotte St, London W1T 4QQ
  • |
  • 0203 488 0184

Privacy Policy


Introduction


We take your privacy very seriously. You should read this privacy policy carefully as it includes important information about how we will collect and use your personal data. We are committed to putting you in control of your privacy, whilst also making sure that the HNW Lending platform is secure.

This document contains important information about some of our key responsibilities. These include protecting against fraud and money laundering and ensuring we comply with other crime prevention measures. We are also committed to careful credit assessment, using manual and automated data collection, and to checking the identity of all users of the HNW Lending platform.

This policy applies to information we collect about:

  • Visitors to our website
  • People who use the HNW Lending platform
  • Any other people who we do business with or who register with us

The legal basis for processing the personal data will be for

  • The performance of a contract (personal information needed to sign up to the site and entering into loans)
  • Compliance with a legal obligation (AML/KYC requirements)

If you do have any questions about this policy or about the use of your data, please feel free to contact us by email



The type of information we collect and use


In order for us to be able to offer a full range of services and products, we may collect and process data about you and how you communicate and interact with us. This will include any information provided to us by you, from other sources (such as a third party credit reference agency) or generated through your use of our services and/or the HNW Lending platform. The type of information collected may include:

  • Personal information such as your name, address and date of birth
  • Financial information such as your bank account number and sort code, details from your credit file and a record of payments made to or from HNW Lending
  • Sensitive information such as any medical information you disclose to us (although we will always get specific permission from you before recording this type of information)

You are responsible for providing accurate and up-to-date information to us and for informing us of any changes to your details



How we will use your information


We gather information about you so that we can provide the services and products that you may request from us. Data can be collected throughout your interaction with us, whether you are using our service through the HNW Lending website or through a partner platform or website. For example:

  • If you register with us as a lender or borrower, we will store your details and use these to verify your identity.
  • We will use your details to conduct an anti-money laundering search on you and we will store the details and the results of the check.
  • When we check your identity or assess your application, we may ask you to provide us with additional information or documentation, we will also store copies of this information.
  • If you decide to borrow or lend through the HNW Lending platform, we will make and store records about your account administration, including copying and/or storing any letters, emails or other communications that we send to each other.
  • We may monitor and record communications with you (such as telephone calls and emails) for quality assurance, training, fraud prevention, debt collection and compliance purposes.
  • Where you borrow money through the HNW Lending platform, we will keep details of your payment record.
  • For lenders we will store a copy of payments made to and from us as well as any documentation required for ISAs such as the account opening form, transfer forms and transfer history forms.
  • When you stop using the HNW Lending platform, we will store information we collected about you for legal, compliance and operational purposes.

If you give us false or inaccurate information, and fraud is identified, we will pass these details to fraud prevention agencies to protect against fraud and money laundering.

We may share information (both within the UK and, where appropriate, overseas) with debt recovery, fraud prevention and law enforcement agencies, and other relevant organisations including other lenders.

We may also share information for the purposes of meeting our legal obligations, recovering debt, preventing crime, verifying your identity and carrying out retrospective analysis of loan applications to enable us to make better informed and responsible decisions. This may mean that we have to share your information with UK or overseas governmental or regulatory authorities or with other similar bodies.

We and other organisations may access and use the information recorded by fraud prevention agencies both in the UK and overseas. If you require details of the fraud prevention agencies we use, please email us.



Information we share


We do not sell or share your data with third parties unless we have your consent to do so or it is necessary for the operation and management of our business and your account. For example, we may need to share your information:

  • With agents, debt collectors or legal representatives who we instruct to collect money that is owed to us.
  • With regulators or government authorities (such as the Financial Conduct Authority, Financial Ombudsman Service, the police, law enforcement agencies) where they ask us for information. We have to share information with these organisations to comply with our regulatory and legal responsibilities.
  • To administer your account. For example, to investigate a complaint, we may discuss your account with third parties involved or party to the transaction (this might include brokers, credit intermediaries or debt collection agents).
  • For external processing as we have vendors and service providers who help with some of our processing and storage, including customer communication distribution, debt recovery and anti-money laundering.
  • With other third parties to carry out retrospective analysis of loan applications to enable HNW Lending to make better informed and responsible lending decisions.
  • With lenders so that they may assess whether they wish to lend on particular loans.

If you enter into a loan agreement using the HNW Lending platform, either as lender or borrower, we may share some information with other parties to the contract. For example, we may share information to help us enforce a loan agreement, where someone has been instructed to act in HNW Lending’s place or where the information is required for reporting purposes, including giving updates to lenders on a loan.

If you apply for a loan and we decline your application, we may give you the option to allow us to pass your details to one of our partners who may be able to help. If you consent and we do pass your details on to one of our partners, we will be acting as a credit broker in doing so and may receive a commission from the partner if your application with them is successful.



How we keep your data safe


All data sent from your browser to our websites is encrypted using industry standard SSL. You can tell that this is the case because the web site address begins with HTTPS. Our websites and databases are built using modern technology and are hosted in multiple high security data centres based in the EU. We use firewalls and many other security mechanisms to keep your data safe, which are maintained and monitored by our staff 24/7.

We also have strict policies and technical barriers in place to prevent unauthorized employee access to customer data. Customer data may be stored on PCs used by HNW employees and agents.

Access to your account is through a password protected mechanism. Data is backed up regularly to a secure location. We may transfer your personal information abroad to countries whose data protection laws are less strict, and less protective of your rights than in the UK, but we will always take steps to ensure we do so securely.

We will use all reasonable efforts to safeguard your personal data, you should be aware that the use of the internet is not entirely secure and therefore we cannot guarantee the security or integrity of any personal information that is transferred from you or to you via the internet or held on our systems.



Accessing your information


You have the right to request a copy of any information we hold about you. If you would like a copy of all or some of the information we have, please contact us by email or by writing to us at the address detailed on our website. Your request may take up to 28 days to fully process.



Consent


By submitting your personal information to us, you consent for us to use that information as set out in this policy.



Contacting us, Our marketing and opting out


We may get in touch from time to time with information about special promotions, new products or any other service we think may be of interest to you. If you decide you do not want to receive this sort of information from us, you can “opt out” from receiving marketing communications from us by contacting us by email or by using the ‘Unsubscribe’ link displayed on any marketing email communications or by reviewing your contact preferences in your HNW Lending account. If you opt out, you will still receive service information about your account but will not get any notices of any special promotions or new products that we might be offering.



Links to third party websites


Our website may contain links to other websites. Our Privacy Policy does not apply to other websites so if you access links to other websites you should read that website`s privacy policy.



Cookies


Our website uses cookies. Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. Cookies allow us to distinguish you from other users of the website helping us to provide you with a good experience when you browse our website and also allowing us to improve our website.

See our Cookies policy, for further information on Cookies and how we use them.



Changes to this Privacy Policy


We will regularly review this Privacy Policy. If we make any changes we will post the updated policy on this page. This Privacy Policy was last updated: 15 May 2018.