This policy will explain how we look after your personal data when you visit our websites and use our services and explain your privacy rights and how the law protects you.
This website is not intended for children, and we do not knowingly collect data relating to children.
Who we are and contact details
If you require any further information or wish to contact us or our Data Protection Officer (DPO) at any time, our contact details are:
Address: Ahauz, WeWork, Shoreditch Exchange, Senna Building, Gorsuch Pl, London E2 8JF
If you have a complaint about anything to do with your data, use those same contact details to get in touch. We’ll investigate and get back to you as soon as we can.
We’re registered with the Information Commissioner’s Office (ICO), the UK regulator for data protection issues, with the registration number ZA315208. You have the right to make a complaint at any time to the ICO however we’d love the chance to help you first, so please contact us in the first instance.
If we cannot resolve a complaint that relates to the way we have handled your personal information to your satisfaction, you can contact the ICO at www.ico.org.uk or by telephone at 0303 123 113.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (known as anonymous data).
We may collect, use, store and transfer different kinds of personal data about you. This can be grouped as follows:
- Identity Data this includes first name, maiden name, last name, marital status, title, gender, nationality and date of birth.
- Contact Data this includes personal addresses, email address and telephone numbers.
- Financial Data this includes bank account details, card payment details, available savings, details of your employment and salary, credit history, financial commitments, and other expenses.
- Transaction Data this includes details about payments to and from you and transactions you carry out using our products and services.
- Documentary Data this includes passport details, driving licence or other identification documents.
- Usage Data this includes information about how you use our website, products and services.
- Technical Data this includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data this includes, your username and password, products and services you use, your interests, preferences, feedback and survey responses.
- Marketing and Communications Data includes your preferences for receiving marketing from us and our business partners and your communication preferences.
- Other Data this includes any other personal data we collect from you during the provision of our services.
If you’re making a joint application, we’ll also collect some of this information about the person you’re applying with, like your spouse. Make sure you have their agreement before you give us their data.
If you fail to provide personal data
Where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with a loan). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
How we collect your personal data
We collect your personal data from and about you in several ways, including through:
- Direct interactions. When you give us the personal data by filling in forms or corresponding with us via phone, email, post or otherwise. This includes the personal data you provide when you apply for our services or products, create an account on our website, subscribe to our publications, request marketing to be sent to you, give us feedback, take part in a survey or, contact us.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources such as:
- Technical Data from analytics providers such as Google, Facebook, LinkedIn; advertising networks such as Google, Facebook, LinkedIn; and search information providers such as Google [Inside the UK/EU].
- Contact, Financial and Transaction Data from providers of technical, payment and credit reference services such as TransUnion International UK Limited based inside the UK/EU.
- Contact, Financial and Transaction Data from mortgage intermediaries based inside the UK/EU.
- Identity and Contact Data from data brokers or aggregators, GoCardless Limited based inside the UK/EU.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
How we use your personal data
We will only use your personal data when the law allows us to. The legal reason that allows us to use your data is called a “lawful basis”. Most commonly, we will use your personal data in the following circumstances:
- Where you have given us consent to use your data.
- Where we need to use the data to perform the contract.
- Where we need to use it to comply with a legal obligation.
- Where its use is necessary for our legitimate interests.
The four types of lawful basis that we will rely on to process your personal data are explained further below:
- Consent means you have told us it is okay to use your personal data for a specific reason.
- Contract means using your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Legal Obligation means processing your personal data where it is necessary for us to do so to comply with the law or regulations.
- Legitimate Interests means the interest of our business in conducting and managing our business to enable us to give you the best services and products and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact it would have on you (unless we have your consent or are otherwise required or permitted to by law). One example of a legitimate interest for processing your data is to try to detect and prevent fraud.
Purposes for which we will use your personal data:
|The purpose or activity for which we use your data
|Type of data
|The legal basis of the purpose
|To register you as a new Ahauz customer
To provide you and improve our services, which will include:
|To assess your application for a loan, including checking your credit history and score
To manage our relationship with you, which will include:
To service the loan, which will include:
|To work with others to help you through the loan and home-buying process, such as brokers who can advise you if our loan is right for you
|To administer and protect our business and this website, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data
|To record our communications to check your instructions and ensure the quality of service, as well as train our staff and improve our services
|To use data analytics to improve Ahauz, including improving our website, products/services, marketing, customer relationships and experiences
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Who we share your data with
We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
Below is a list of third parties we might need to share your data with:
- Ahauz group companies. These are companies controlled by Ahauz. We might share your data with other Ahauz group companies if they provide services to us. We might also do so for marketing purposes where you’ve agreed to it.
- Regulators, governmental or dispute resolution bodies, law enforcement agencies, or other similar authorities.
- Anyone acting on your behalf with authority to do so, such as a debt charity, power of attorney, or your professional advisors.
- Credit reference agencies (CRAs), companies that hold your credit history and credit score and check your identity when you apply for a mortgage, and on an ongoing basis for fraud prevention purposes.
- Fraud prevention agencies, to check your identity when you apply for a mortgage, and on an ongoing basis.
- Other service providers that support Ahauz such as Automated Valuation Model and IT providers and legal and accounting firms.
- Debt collection agencies to seek to recover any debt owed to us.
- Other financial service companies, such as your first charge lender.
- Third parties, such as mortgage brokers and conveyancing solicitors, or who have introduced you to us or are involved in the introduction process (e.g. an intermediary, broker, network, or Mortgage Club).Any person or entity that is to provide, or has provided, any security or guarantee (and their professional advisors) in respect of your agreement with us and their professional advisors.
- Any entity (and their professional advisors) that provides funding to Ahauz group companies, and any entity that provides us with debt or equity finance.
- Any purchaser or potential purchaser of any part of our business in the event that Ahauz, or part of its assets was to be acquired by a third-party purchaser.
- We use Contact State to confirm your sign up request has been generated by a real person and not a robot. As part of this form submission, we send Contact State some limited information about this session. For more information, please read Contact State’s Information Notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Credit Reference Agencies (CRAs)
In order to provide you with our products or services, we will obtain your credit score and credit report, perform credit and identity checks on you with one or more CRAs. We will also carry out further periodic searches at CRAs to allow us to manage your account with us or provide our services.
To do this, we will share your personal information with CRAs, and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. CRAs will supply us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.
We will use this information given to us by the CRAs to:
- Assess the value of your home equity;
- Assess your creditworthiness and whether you can afford to take a product;
- Verify the accuracy of the data you have provided to us;
- Prevent criminal activity, fraud and money laundering;
- Manage your account(s);
- Trace and recover debts;
- Ensure any offers provided are appropriate to your circumstances.
We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. 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.
When CRAs receive a search from us, they will place a search footprint on your credit file that may be seen by other lenders.
If you are making a joint application or tell us that you have a spouse, civil partner or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. CRAs will also link your records together and these links will remain on your and their files until you or your partner successfully files for a disassociation with the CRAs to break that link.
The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail in the CRA information notice (CRAIN) which is accessible from CRA we work with TransUnion, please see their website www.transunion.co.uk/crain for further details.
International transfers of your personal information
We take the security of your personal information seriously and have implemented appropriate technical measures to protect it against unauthorised or unlawful processing and against accidental loss, destruction, or damage.
We work with partners in the UK, in the European Economic Area (EEA), and in countries outside the EEA.
If we transfer your personal information to anyone outside the EEA, we’ll ensure appropriate safeguards are in place to maintain the same levels of protection as are required under data protection laws in the UK and as determined by the European Commission. We do this by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
For more information about how we protect your data across borders you can contact us at email@example.com.
How long we keep your personal data
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. Our business relationship will be deemed to be at an end on the date upon which your account is closed (which will either be when all outstanding sums under the agreement have been repaid or when we stop pursuing arrears on the account) or when your application for a loan has been declined.
In some circumstances, you can ask us to delete your data. See your legal rights outlined below for further information.
Please note that if your personal information is shared with third parties, they may have different retention policies.
In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Keeping your information secure
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Your legal rights
You have rights when it comes to your personal data under the UK GDPR, which is a data protection law. Please click on the links below to find out more about each of these rights:
- You have the right to be informed about the collection and use of your personal data.
- You have the right to access and receive a copy of your personal data, and other supplementary information.
- You have the right to have inaccurate personal data rectified, or completed if it is incomplete.
- You have the right to have personal data erased in certain circumstances.
- You have the right to request that organisations restrict their use of your personal data.
- You have the right to data portability which allows you to obtain and reuse your personal data for your own purposes across different services.
- You have the right to object to the processing of your personal data in certain circumstances.
- You have rights related to automated decision making including profiling.
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org.
No fee is usually required
You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee for the administrative costs of complying with your request if it is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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 and keep you updated.