Privacy Policy

www.consumercreditapplication.co.uk, contact us, complete our requirements checker or use our services.

We process personal information in accordance with applicable UK data protection legislation, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003, as amended.

1. Who we are

Consumer Credit Application is a trading name of Comply Academy Ltd, a company registered in England and Wales with company number 14475158, whose registered office is at 1 Kings Avenue, Winchmore Hill, London, N21 3NA.

Comply Academy Ltd is the data controller responsible for the personal information covered by this policy. References to “Consumer Credit Application”, “we”, “us” and “our” mean Comply Academy Ltd trading as Consumer Credit Application.

For customer support, privacy enquiries, data protection complaints or requests to exercise your rights, contact:

Email: info@consumercreditapplication.co.uk
Post: Privacy Enquiries, Comply Academy Ltd, 1 Kings Avenue, Winchmore Hill, London, N21 3NA

2. Who this policy covers

This policy applies to website visitors, people making enquiries, prospective and existing clients, and individuals whose information is provided in connection with our services. These may include directors, owners, controllers, employees and business representatives.

Our services support businesses assessing or preparing FCA consumer credit applications. They are not personal loan application services.

Where we process personal information solely on a client’s behalf as a data processor, we act under the client’s instructions and the applicable data processing agreement. The client is responsible for explaining that processing in its own privacy information.

3. Personal information we collect

Depending on how you interact with us and the service requested, we may collect:

• Identity and contact information: your name, email address, telephone number, postal address, job title and business details.
• Enquiry information: messages, questions, requirements checker answers and information about your business activities and finance arrangements.
• Service and application information: information and supporting documents relevant to the agreed work, which may include details about directors, owners, controllers and relevant staff, CVs, employment history, qualifications and financial information.
• Order and transaction information: services purchased, billing details, invoices, payment status, transaction references and refund records.
• Communication records: correspondence, instructions, feedback, complaints and records of our work.
• Technical information: IP address, browser and device information, website security logs and information about your interaction with the website.
• Preferences: marketing choices, cookie preferences and consent records.

We seek to collect only information that is relevant and necessary for the particular purpose.

4. How we collect personal information

We may obtain personal information:

• directly from you through website forms, questionnaires, orders, emails, correspondence and documents;
• from the business instructing us, your colleagues or authorised representatives;
• from relevant public sources, such as Companies House and the FCA Financial Services Register;
• from service providers supporting transactions, website security and service delivery; and
• through cookies and similar technologies, as explained in our Cookie Policy.

If you provide information about another person, you should have a lawful basis for sharing it and make this policy available to them. This does not replace our own obligations to provide privacy information.

5. How we use personal information

We use personal information to:

• respond to enquiries and communicate with you;
• assess your requirements and the suitability of our services;
• provide permission analysis, application preparation, application review and related support;
• prepare and review documents using the information supplied;
• administer orders, payments, invoices and refunds;
• maintain appropriate business and service records;
• operate, maintain and protect our website and systems;
• investigate complaints and resolve disputes;
• comply with applicable legal requirements; and
• send optional marketing communications where you have consented.

6. Our lawful bases

We identify an appropriate lawful basis for each use of personal information.

Contract

We rely on this basis where processing is necessary to perform a contract with you personally, or to take steps at your request before entering into that contract.

Legitimate interests

We may rely on legitimate interests to respond to business enquiries, deliver services to a company you represent, administer business relationships, protect our systems, prevent misuse and establish, exercise or defend legal claims.

We assess whether the processing is necessary and balance these interests against your rights and reasonable expectations.

Legal obligation

We rely on this basis where processing is necessary to comply with a legal obligation, including applicable accounting and tax requirements or legally binding requests.

Consent

We rely on consent for optional marketing communications and for cookies or similar technologies where consent is required.

You can withdraw consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

Where information is necessary to provide a service or meet a legal requirement, we will explain this when requesting it. Without the necessary information, we may be unable to proceed.

7. Sensitive information and criminal records

Some application-related information may include special category information, such as health information, or information about criminal convictions and offences, including DBS records.

Please do not provide this information unless we have specifically requested it and explained how to send it securely.

Before collecting or using such information, we identify the applicable lawful basis and additional legal condition required for that processing. We provide further privacy information about the purpose, relevant condition, sharing and retention where appropriate.

We do not treat submission of information through our website as explicit consent to process sensitive information.

8. Sharing personal information

Where necessary and lawful, we may share relevant information with:

• providers of website hosting, IT support, email, document storage, security and business administration services;
• payment providers and banks involved in processing transactions;
• consultants or specialists engaged to help deliver the agreed service;
• accountants, legal advisers, insurers and other professional advisers;
• the FCA or other relevant authorities where disclosure forms part of the agreed service or is legally required; and
• courts, law enforcement bodies or other recipients where disclosure is legally required or necessary and lawful to protect legal rights.

We limit sharing to information relevant to the purpose.

Where providers process information on our behalf, we put appropriate contractual arrangements in place. Where a recipient acts as an independent data controller, its own privacy notice applies to its processing.

We do not sell personal information.

9. International transfers

The use of service providers or specialists may involve storing or accessing personal information outside the United Kingdom.

Where this involves a restricted international transfer, we ensure that an appropriate transfer mechanism applies. This may include:

• UK adequacy regulations covering the destination or recipient; or
• appropriate contractual safeguards, such as the UK International Data Transfer Agreement or the UK Addendum to the European Commission’s Standard Contractual Clauses, together with any necessary assessments and additional protections.

Contact info@consumercreditapplication.co.uk for information about overseas processing relevant to your information, the safeguards used and how to obtain a copy, subject to appropriate redactions.

10. How long we retain information

We retain personal information only for as long as necessary for the purpose for which it was collected.

We determine retention periods by considering:

• whether an enquiry or engagement remains active;
• the information needed to deliver and evidence our work;
• applicable accounting, tax and other legal requirements;
• relevant time limits for legal claims;
• any ongoing complaint, investigation or dispute;
• the sensitivity of the information and the risks of retaining it; and
• whether the purpose can be achieved with less information.

Supporting documents may be deleted earlier than core engagement records where they are no longer needed. We do not automatically retain every document for the same period.

We retain marketing information until you withdraw consent or we determine that it is no longer needed. We may keep minimal suppression records to ensure that we respect your request not to receive marketing.

When information is no longer required, we securely delete or anonymise it. Backup copies are removed in accordance with the applicable backup retention cycle.

11. Cookies and similar technologies

Our website uses cookies and similar technologies.

Information about the technologies used, their purposes, providers, durations and available controls is set out in our Cookie Policy.

Where consent is required, the relevant technologies are not activated until you consent. You can refuse or withdraw consent through the website’s cookie controls.

Where a legal exception permits use without consent, we provide the information and any objection mechanism required by that exception.

12. Marketing communications

We send optional marketing emails only where you have opted in.

You can withdraw your consent at any time by using the unsubscribe option in the message or emailing info@consumercreditapplication.co.uk.

Withdrawing marketing consent does not affect necessary communications about your enquiry, order, service or complaint.

13. Requirements checker and automated tools

Our requirements checker uses the answers you provide to give an initial indication of possible requirements or suitable services.

Its output is preliminary, depends on the accuracy and completeness of your answers, and does not constitute an FCA authorisation decision. Authorisation decisions are made solely by the FCA.

If we introduce solely automated decisions that have legal or similarly significant effects on individuals, we will provide the required information about how those decisions work, their likely consequences and the applicable rights and safeguards before carrying out that processing.

14. Information security

We use appropriate technical and organisational measures designed to protect personal information against unauthorised access, accidental loss, misuse, alteration or disclosure.

Access is limited to people who need the information for their work and who are subject to appropriate confidentiality obligations.

No internet transmission or storage system can be guaranteed completely secure. Please contact us before sending sensitive documents so that we can explain the appropriate transfer method.

15. Your data protection rights

Depending on the circumstances and applicable legal conditions, you may have the right to:

• obtain a copy of your personal information and information about how it is used;
• correct inaccurate or incomplete information;
• request deletion of information;
• restrict its use;
• receive certain information in a portable format; and
• withdraw consent where processing relies on consent.

These rights are subject to applicable conditions and exemptions. For example, we may need to retain certain information to comply with a legal obligation or deal with legal claims.

Your right to object

You may object to processing based on legitimate interests for reasons relating to your particular circumstances. We will stop that processing unless we can demonstrate overriding lawful grounds or the information is needed for legal claims.

You can object to the use of your personal information for direct marketing at any time. We will stop using it for that purpose.

To exercise your rights, email info@consumercreditapplication.co.uk. You do not need to use a particular form.

We normally respond without undue delay and within one month. Where the law permits additional time, we will explain the reason and applicable timeframe. We may request proportionate information to verify your identity or authority.

Requests are normally free. Where a lawful exemption, refusal or charge applies, we will explain this and your options for challenging our response.

16. Privacy complaints

If you are concerned about how we handle personal information, contact:

Email: info@consumercreditapplication.co.uk
Post: Privacy Enquiries, Comply Academy Ltd, 1 Kings Avenue, Winchmore Hill, London, N21 3NA

Please describe your concern and provide any relevant details.

We will acknowledge your complaint within 30 days, make appropriate enquiries without undue delay, keep you informed of progress and communicate the outcome without undue delay.

You also have the right to complain to the UK Information Commissioner’s Office:

Website: ico.org.uk/make-a-complaint

You do not need our permission to contact the ICO.

17. External websites

Our website may contain links to third-party websites. Those organisations are responsible for their own processing of personal information.

Please read their privacy notices before providing personal information to them.

18. Changes to this policy

We review this policy and update it when necessary. The latest version will appear on this page with its update date.

Where a change materially affects how we use your personal information, we will take appropriate steps to bring it to your attention and provide any further information or obtain any consent required before the new processing begins.