Instaloans Privacy Policy

Instaloans is a trading name of Monva Limited. Monva Limited is authorised and regulated by the Financial Conduct Authority.

Introduction

This privacy notice provides you with details of how we collect and process your personal data through your use of our site  www.instaloans.co.uk.

By providing us with your data, you warrant to us that you are over 18 years of age. Monva Limited are the data controller. Our data controller registration number is ZA442945. You can check our registration on the Data Protection Public Register by visiting  https://ico.org.uk/esdwebpages/search.

We are responsible for your personal data (referred to as “Instaloans”, “we”, “us” or “our” in this privacy notice). References to “you” and “your” means each natural or legal person who uses our website or the associated services. 

We have appointed a Data Protection Officer who is in charge of privacy related matters for us. If you have any questions about this privacy notice, please contact the Data Protection Officer using the details set out below.

Contact Details for Monva Limited:

Email: privacy@monva.co.uk

Post: Data Protection Officer, Monva Limited, Office D First Floor, Parkway Business Centre, Deeside Industrial Estate, Deeside, CH5 2LE.

What data do we collect about you, for what purpose and on what ground we process it?

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process the following categories of personal data about you:

  • Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
  • Customer Data that includes data relating to any applications you may make as your Title, Name, Date of birth, Email address, Phone number, Employment status, Income, Expenditure, Residential address, Address history, Property value, Mortgage term, Mortgage amount, Years left on mortgage, Current monthly repayments, Current mortgage balance and Bank Details. We process this data to supply our services to you and to keep records of our interactions. Our lawful ground for this processing is the performance of an arrangement between you and us and/or taking steps at your request to enter into such an agreement.
  • Credit Reference Agency Data.  If you use our services, we may obtain your credit score and credit report from one or more credit reference agencies on your behalf. Our lawful ground for this processing is to enable us to supply services to you and our legitimate interests, which in this case are to properly administer our website and our business.
  • Data from Other Sources.  We may receive information about you if you use any of the websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, service providers, advertising networks, analytics providers, search information providers, social media) and may receive information from them, whether or not you have taken out a product with them, what other products you may have used, and other such details. Our lawful ground for this processing is to enable us to supply services to you and our legitimate interests, which in this case are to properly administer our website and our business.
  • User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
  • Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
  • Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. You can opt out easily of receiving marketing from us at any time. We will normally send direct marketing by email if we have your email address but may choose to contact you via other methods. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
  • We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

Sensitive Data

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the agreement (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have requested but if we do, we will notify you at the time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at privacy@monva.co.uk. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

Automated Decision Making

We may use an automated decision making system. This helps us to make sure our decisions are quick and fair, based on what we know.

  • Identity verification. We use an automated decision making system to verify the details you provide against those held by third party providers.
  • Personalised products and services. We may use your information to predict the probability that you may be accepted for a product.
  • Personalised communications. We want to make sure we only send you emails that are relevant, and so we will use your personal information to determine which content you may be more interested in receiving.

You have the right not to be subject to a decision based solely on automated processing, including profiling. We understand that not everyone is comfortable with automated processing. If you have any questions about automated decision making, please contact us at privacy@monva.co.uk.

In summary, the information you give to us or we collect from other third parties on your behalf as part of our services will be used:

  • manage your relationship with us and to, communicate with you by telephone, mail, email, text (SMS) message or other electronic means
  • verify your identity
  • provide you with information, products and services
  • where you have provided your consent for us to market to you, provide you with information about other products and services we feel may interest you or be best for you
  • notify you about changes to our services
  • ensure that content from our website is presented in the most effective manner
  • aggregate it on an anonymous basis with other data for data analytical and reporting purposes
  • undertake analysis and profiling of your credit information in order to identify and inform you of credit products that we consider are likely to interest you or be suited to your credit circumstances

How we collect your personal data

We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our Cookie Policy for more details about this.

We may receive data from third parties such as credit reference agencies, fraud prevention agencies, product providers, analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.

We may also receive data from publicly availably sources such as the Electoral Register and Companies House based inside the EU.

Marketing communications

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you asked for information from us about our goods or services or made a purchase, or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.

You may receive the following types of communications from us:

  • Product recommendations – we may get in touch with personalised, timely product recommendations that can help you improve your financial situation. We will only ever send these if you explicitly consent to receiving them and you can unsubscribe whenever you like.
  • Content communications – we may send you content such as tips, research, features and news. You can unsubscribe from these at any time and we will never spam your inbox.
  • Core communications – we may send you alerts whenever there is a change to your circumstances or available products or services, significant changes which may impact our service and other such related content.

If you would like us to stop sending direct marketing to you, we offer simple ways to do this. Whenever you receive direct marketing you will be given an option to unsubscribe.

You can also tell us that you do not wish to receive any more marketing communications at any time by writing, with your full name, address and other contact details (to enable us to find your records), to:

Data Protection Officer, Monva Limited, Office D First Floor, Parkway Business Centre, Deeside Industrial Estate, Deeside, CH5 2LE.

Before we share your personal data with any third party for their own marketing purposes we will get your express consent. You can ask third parties to stop sending you marketing messages at any time by logging into their website and checking or unchecking relevant boxes to adjust your marketing preferences, or by following the opt-out links on any marketing message sent to you.

Disclosures of your personal data

We may share your personal data with the parties set out below:

  • Credit Reference Agencies, to obtain your credit score and credit report on your behalf and to provide our services to you (see “Credit Reference Agencies” section below for more detail)
  • Fraud prevention agencies, to prevent crime and trace those responsible (see “Fraud Prevention Agencies” below for more detail)
  • Product providers, such as our business partners who offer you credit cards, loans, car finance, mortgages and other related products, to:
  • assess if you are an existing customer and for fraud prevention purposes
  • conduct analysis to provide you with better products and services in the future, and for segmentation purposes
  • pre-fill an application form with the product provider
  • assess your probability of being accepted for a product

When you click to search for credit card and/or loan offers on our website or our apps, these product providers may record a ‘soft credit search’ on your credit file, but this record will be invisible to other lenders, so by itself it will not affect their lending decision and it will not affect your credit score.

The product provider does not have permission to use this data for any other purpose including marketing.

Our Brokers are currently: Nouveau Finance Limited, T Dot UK Limited, Mindflow Marketing Limited.

Our Guarantor Lenders are currently: Amigo Loans, Bamboo, UK Credit.

Our Lenders are currently: Bamboo, Lendable, Lending Works, Likely Loans, My Community Bank.

  • Advertisers that require the aggregated data (whereby individuals cannot be individually identified), to perform services on our behalf, including selecting and serving relevant adverts
  • Analytics and search engine providers that assist us in the improvement and optimisation of our service
  • If we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets (or the buyer or seller’s advisers)

If we or part or all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and other agreements; or to protect the rights, property, or safety of Monva Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Service providers who provide IT and system administration services. Professional advisers including lawyers, bankers, auditors and insurers Government bodies that require us to report processing activities.

Third parties to whom we sell, transfer, or merge parts of our business or our assets.

Subprocessors

We may share your information with the following sub-processors:

Entity Name Activities
Nouveau Finance Limited Lender Panel Provider Integration
T Dot UK Limited Lender Panel Provider Integration
Mindflow Marketing Limited Lender Panel Provider Integration
Accepty Technology Limited Lender Panel Provider Integration
AWS Website Hosting
SendGrid Marketing Automation Platform

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

Credit Reference Agencies

If you use our services we may obtain on your behalf, copies of your credit report and credit score from designated Credit Reference Agencies (CRA). In order to provide these services to you, we will share your information with such Credit Reference Agencies.

The information which we provide to the CRA may be supplied by them to other organisations such as Fraud Prevention Agencies and used by those organisations for the purposes of checking identity, preventing fraud, tracing and collection of debt. The CRA may also use the data to undertake statistical analysis.

If you choose to apply for a product, the product provider will undertake a full credit check and provide you with further privacy information for that product. More information about each CRA and what it does with personal data is available here - https://www.equifax.co.uk/crain.

Fraud Prevention Agencies

We may source and share your personal information with fraud prevention agencies. If false or inaccurate information is provided and fraud is identified, details of this fraud will be passed to these agencies. Law enforcement agencies may access and use this information.

International Transfers

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

A small number of our third parties service providers may conduct activities outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:

  • We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
  • Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
  • If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Data Security

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions, and they must keep it confidential. We can’t guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use security measures to prevent unauthorised access, loss or damage.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your Legal Rights

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at privacy@monva.co.uk.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (https://ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

Third-Party Links

Our website includes links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Cookies

We and our partner service providers collect information about your use of our website from cookies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Changes to privacy policy

Any changes to our Privacy Policy will be updated on this page and, where we decide it’s appropriate, notified to you by email.

Last updated: 08/11/2019