Wageme is committed to protecting and respecting your privacy.
Wageme and what we do
Wageme – An FCA Authorised lender in High Cost Short-term loans.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our websites you are accepting and consenting to the practices described in this policy.
For the purpose of the Data Protection Act 2018 (‘DPA’) and the EU General Data Protection Regulation (‘GDPR’) , the data controller is Wageme.com Ltd Registered Office: 53 Greek St, W1D 3DR, London, United Kingdom
This Privacy Statement explains how we process your information and your rights under both DPA and GDPR.
Information we may collect from you
We may collect and process the following data about you:
Information you give us. such as your name, address and email address.
When you browse our store, we also automatically receive your computer’s internet protocol (IP) address in order to provide us with information that helps us learn about your browser and operating system.
Email marketing (if applicable): With your permission, we may send you emails about our store, new products and other updates.
- E-mail address
- Home address
- Residential status
- Employment Details / Status
- Telephone numbers
- Date of birth
- Income details, including your pay dates
- Bank account details
- National Insurance number
Information we receive from other sources.
We are working closely with other organisations (including, for example, business partners, sub-contractors in technical and payment services, advertising networks, analytics providers, search information providers, credit reference agencies). In using analytics tools such as Google Analytics, data may be collected by the third party providing the tool and passed back to us for analysis. Further information on our payment providers can be found in the ‘Where we store your personal data’ section below.
Uses made of the information
We use information held about you in the following ways:
Information you give to us. We will use this information:
- To verify your identity and credit standing and to enable us to consider and process your application for a loan or other products or services.
- To assess your credit history and confirm your employment details.
- To detect, prevent and investigate actual and potential fraud and related activities
- To collect unpaid loans and debt that may be owed by you to us.
- To develop, manage and market products and services to meet your needs, to contact you for products and services that may be of interest, to determine your eligibility for different products and services that you may be interested in.
- To help us to administer and service your account with us.
- To contact you in connection with your enquiry.
- To extract certain information for the purpose of generating statistics for our own internal purposes (including credit and/or behaviour scoring, and market and product analysis).
- To update our website to better meet our clients’ needs in the future.
Information we collect about you. We will use this information:
to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve our site to ensure that content is presented in the most effective manner for you and for your device;
to allow you to participate in interactive features of our service, when you choose to do so;
as part of our efforts to keep our site safe and secure;
to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
subject to the express consents referred to above, to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them;
for fraud purposes and to spot suspicious activity.
Information we receive from other sources
We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
Disclosure of your information
To provide you with a loan. As brokers as well as direct lenders, our products and services are sometimes provided in conjunction with our business partners. It will therefore be necessary to disclose your information to them to provide you with the products and/or services you require.
f your loan application with us is unsuccessful, and you consent to us doing so, we may pass your application details to credit brokers, including Nouveau Finance Limited, a credit broker authorised by the FCA (authorisation number 727348), Greenfield Capital II Ltd and is authorised and regulated by the Financial Conduct Authority (FCA Ref No: 790935),Kind Commercial Limited (FCA Ref No: 717766), so that they may help you find a suitable lending solution by providing your details to lenders on their panels. These lenders may carry out additional credit searches in order to assess whether they are able to offer you a loan and you may be contacted by SMS, email, telephone or automated message by any lender that has approved your application for the purpose of progressing your application with them.
Note that in passing your details to credit brokers, WageMe is itself acting as a credit broker (i.e. an introducer) and will receive a commission directly from the credit broker following a successful introduction.
To our agents, staff and approved third parties to carry out services for us. To facilitate the processing and collection of direct debits or other payments due from you under the loan agreement, we may also share your personal data with third party payment processing service providers. These companies are authorized to use your personal information only as necessary to provide these services to us.
To provide you with information about special promotions and offers as referred to in the “Keeping You Informed” section below.
To protect us, our group of affiliated companies or others. We may share your information as required by law, such as to comply with a subpoena, or similar legal process, with third parties when we believe it is necessary to protect our or another person's rights, property, or safety. This includes exchanging information with third parties (such as other lenders, law enforcement agencies and regulatory authorities) to protect against fraud and reduce risks.
If there is (or is to be) any change in ownership of our business or assets then we may wish to share your information so that the new (prospective) owners may continue to operate our business effectively and continue to provide services to our customers. This may include new shareholders or any organization that might take an assignment or transfer of any agreements we have entered into with our customers. you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information We will place appropriate obligations and restrictions on third parties to protect your details.
In some circumstances, your details may be passed to another lender (not necessarily within our group of affiliated companies) who may be able to offer you a payday loan. Please refer to the relevant pages within the loan application process for further information.
From time to time we would like to contact you with offers relating to products of ours which we think you might be interested in, by SMS, post, email, telephone or automated message. Please tick the appropriate box on the application if you wish to receive marketing material from us or contact us at Wageme.com 53 GREEK STREET, LONDON, W1D 3DR to inform us of your marketing preferences.
We may share your information with selected third parties including:
Business partners, suppliers and sub-contractors for the performance of any contract we enter into with [them or] you, including without limitation any data processor we engage.
Analytics and search engine providers that assist us in the improvement and optimisation of our site.
We may disclose your personal information to third parties:
In the event that 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.
Where we store your personal data
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Your rights under Data Protection Law
The DPA and GDPR apply to ‘personal data’ we process and the data protection principles set out the main responsibilities we are responsible for.
We must ensure that personal data shall be:
a) processed lawfully, fairly and in a transparent manner;
b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
d) accurate and where necessary kept up to date;
e) kept for no longer than is necessary for the purposes for which the personal data are processed. We operate a data retention policy that ensures we meet this obligation.
We only retain personal data for the purposes for which it was collected and for a reasonable period thereafter where there is a legitimate business need or legal obligation to do so. For detail of our current retention policy contact our privacy officer at firstname.lastname@example.org
f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
We ensure lawful processing of personal data by obtaining consent; or where there is a contractual obligation to do so in providing appropriate products and services; or where processing the data is necessary for the purposes of our legitimate interests in providing appropriate products and services.
In the majority of cases we process personal data based on your contract with the us. In other cases, we process personal data only where there are legitimate grounds for so doing.
To meet our Data Protection obligations, we have established comprehensive and proportionate governance measures.
We ensure data protection compliance across the organisation through:
a) implementing appropriate technical and organisational measures including internal data protection policies, staff training, internal audits of processing activities, and reviews of internal HR policies.
b) maintaining relevant documentation on processing activities.
c) implementing measures that meet the principles of data protection by design and data protection by default including data minimisation, pseudonymisation, transparency, deploying the most up-to-date data security protocols and using data protection impact assessments across our organisation and in any third party arrangements.
Credit reference & fraud prevention agencies
a. We may use credit reference and fraud prevention agencies to help us make decisions. When you apply to us to open an account, we will check the following records about you and others: our own;
b. We will make checks such as assessing this application for credit and verifying identities to prevent and detect crime and money laundering. We may also make periodic searches at CRAs and FPAs in order to refresh our records and manage your account with us, including whether to make credit available or to continue or extend existing credit, focus the relevance of the marketing communications that we send to you, and/or ensure that we comply with our obligations regarding responsible lending.
c. If you are making a joint application or tell us that you have a spouse or financial associate, we will link your records together so you must be sure that you have their agreement to disclose information about them. CRAs also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.
d. Information on applications will be sent to CRAs and will be recorded by them. Where you borrow from us, we will give details of your accounts and how you manage it/them to CRAs. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs and FPAs to perform similar checks and to trace your whereabouts and recover debts that you owe. Records remain on file for 6 years after they are closed, whether settled by you or defaulted.
e. If you give us false or inaccurate information and we suspect or identify fraud we will record this and may also pass this information to FPAs and other organisations involved in crime and fraud prevention. Law enforcement agencies (such as the police, HMRC and other regulatory bodies) may access and use this information. We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:
Checking details on applications for credit and credit related or other facilities;
Managing credit and credit related accounts or facilities;
Checking details on proposals and claims for all types of insurance;
Checking details of job applicants and employees.
f. If you have borrowed from us and do not make payments that you owe us, we will trace your whereabouts and recover debts.
g. We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.
h. Your data may also be used for other purposes for which you give your specific permission or, in very limited circumstances, when required by law or where permitted under the terms of the Data Protection Act 1998.
i. This section is a condensed explanation of how personal information is used for credit referencing and fraud prevention purposes. If you would like to read the full details of how your credit reference data may be used please refer to “A Guide to the use of your personal information by Wageme.com and at Credit Reference and Fraud Prevention Agencies” by clicking here.
j. You can contact the CRAs currently operating in the UK; the information they hold may not be the same so it is worth contacting them all. They will charge you a small statutory fee, currently £2.00.
CallCredit, Consumer Services Team, PO Box 491, Leeds, LS3 1WZ or call 0870 0601414
Equifax PLC, Credit File Advice Centre, PO Box 3001, Bradford, BD1 5US or call 0870 010 0583 or log on to www.myequifax.co.uk
Experian, Consumer Help Service, PO Box 8000, Nottingham NG80 7WF or call 0844 4818000 or log on to www.experian.co.uk.
Teletrack UK Limited, 6th Floor (South Tower), 26 Elmfield Road, Bromley, Kent BR1 1WA
Perfect Data Solutions Limited(trading as LendingMetrics)Lancaster Court8 Barnes Wallis Road Fareham, PO15 5TU www.lendingmetrics.com.
Please contact our Data Protection Officer (see “Contact Our Data Protection Officer” below) if you want to receive details of the relevant fraud prevention agencies.
k. Information held about you by the Credit Reference Agencies may already be linked to records relating to your partner(s). For the purposes of this application you and your partner(s) are financially independent and you request that your application be assessed without reference to any "associated" records, although you recognise that this may adversely affect the outcome of your application. You believe that there is no information relating to your partner(s) that is likely to affect our willingness to offer financial services to you. You authorise us to check the validity of this declaration with Credit Reference Agencies and if we discover any associated records, which would affect the accuracy of this declaration we may decide not to proceed with the application on this basis.
As a responsible lender, Wageme.com has a legal obligation to take steps to ensure that our customers are creditworthy.
We use a variety of methods to try to make sure that we do not lend money to people who are in financial difficulty. One of these is to carry out a credit reference check. In order to do this, we shall pass the personal data that you provide to us in your loan application to a credit reference agency (CRA) called Perfect Data Solutions Limited which trades as Lending Metrics. Lending Metrics provide us with data about a customer's credit history and borrowing habits. You can contact Lending Metrics at Lancaster Court, 8 Barnes Wallis Road, Fareham, Hampshire, PO15 5TU in writing to request the information that they hold about you (please note, a small statutory fee may be payable).
From 25 May 2018 under the GDPR You have the following specific rights in respect of the personal data we process:
1. The right to be informed about how we use personal data.
This Privacy Statement explains who we are; the purposes for which we process personal data and our legitimate interests in so doing; the categories of data we process; third party disclosures; and details of any transfers of personal data outside the UK.
2. The right of access to the personal data we hold. In most cases this will be free of charge and must be provided within one month of receipt.
3. The right to rectification where data are inaccurate or incomplete. In such cases we shall make any amendments or additions within one month of your request.
4. The right to erasure of personal data, but only in very specific circumstances, typically where the personal data are no longer necessary in relation to the purpose for which it was originally collected or processed; or, in certain cases where we have relied on consent to process the data, when that consent is withdrawn and there is no other legitimate reason for continuing to process that data; or when the individual objects to the processing and there is no overriding legitimate interest for continuing the processing.
5. The right to restrict processing, for example while we are reviewing the accuracy or completeness of data, or deciding on whether any request for erasure is valid. In such cases we shall continue to store the data, but not further process it until such time as we have resolved the issue.
6. The right to data portability which, subject to a number of qualifying conditions, allows individuals to obtain and reuse their personal data for their own purposes across different services.
7. The right to object in cases where processing is based on legitimate interests, where our requirement to process the data is overridden by the rights of the individual concerned; or for the purposes of direct marketing (including profiling); or for processing for purposes of scientific / historical research and statistics, unless this is for necessary for the performance of a public interest task.
8. Rights in relation to automated decision making and profiling.
Please contact our privacy officer at email@example.com for more information about the GDPR and your rights under Data Protection law.
If you have a complaint about data protection at Wageme contact our privacy officer at firstname.lastname@example.org.
Alternatively contact our supervisory authority for data protection compliance (www.ico.org.uk):
Information Commissioner's Office
Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate)
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Last updated: 21/05/2018