Logbook Money Privacy Policy

1.0 Introduction

At Logbook Money Limited (LBM) we always respect your privacy and are committed to protecting it at all times. This policy explains how we collect your data and how it may be used.

How we collect information about you

• Data can be collected and processed when you use our website or when you communicate directly with us, such as by email, phone or letter;
• When you are referred to LBM by Business Partners;
• When you take out a loan directly with LBM, your details will be stored;
• If you take out an agreement with us, we will ask you to provide documents to support your application, such as proof of address and income. Copies of those documents may be made and retained;
• During the life of any agreement we will make notes of any contact, including any personal information you disclose to us during that contact;
• Any calls made to us or our agents may be recorded for training and monitoring purposes; and/or
• After an agreement has been completed, we may keep records of any feedback you give us about the service provided.

The type of data collected may include personal information such as your name, address, telephone numbers, email addresses, date of birth and employment details. It may also include details of contacts or agreements you have had with us in the past or unsuccessful applications for further credit.

You may also disclose sensitive information to us (such as information about your physical and mental health, racial or ethnic origin, political opinions, religious beliefs, sexual life, medical information), which we may hold and process.

You are responsible for providing valid, accurate and up to date information. When you give us information about another individual or organisation, it is on the basis that you confirm that you have specifically agreed to this and understand how and why the information will be used.

2.0 Use of Customer Information

Your data will always be dealt with responsibly and in accordance with the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR). Information stored or collected about you helps us improve our service and helps to make sure that any agreement you have with us is run smoothly. Your information may be used to:

• identify you when you contact us;
• carry out credit checks through licensed credit-referencing agencies, and a record of this search may be made on your credit profile;
• carry out business processes such as valuing your vehicle or assisting you with buying or selling a vehicle, so that we can provide or assist you in obtaining such products and services that you require;
• make credit decisions about you and check that the details you have provided to us are complete and accurate;
• administer and manage any application you make to us and pass your details on to Panel Lenders;
• administer your account with us, in the event you take out credit with LBM;
• monitor and analyse our business, including conducting internal audits, using statistical analysis to develop and improve our products and services and conducting market research;
• contact you by email, text message, post, telephone or in any other way about our products and services. However, we will not pass your details to any third parties for marketing purposes;
• identify, prevent, detect or tackle fraud, money laundering, terrorism and other crimes;
• trace your whereabouts and recover any debt you owe us; and/or
• comply with our regulatory obligations.

Any debit or credit card details you provide to us, either during the loan application or subsequently, will be used to take further payments both on your current loan and on any subsequent loans in accordance with the instructions you have given us.

We keep personal data only for as long as necessary for its purpose and to meet legal or regulatory obligations. Data used for credit reference or affordability checks is retained only for as long as required and then securely deleted.

Before personal information is collected, LBM will consider what details are necessary for the purposes of your application. Information from any previous loan is used to assess any future loan applications, but information will be kept for a maximum of 6 years after the loan has expired, after which time the data will be deleted.

LBM may transfer personal information abroad to countries outside the UK or the EEA but if we do so we will ensure that the information is handled securely and to standards at least as good as in the UK.

3.0 Credit Reference Agency (CRA) Data

LBM will perform credit searches on new applications.

In the cases where credit referencing is undertaken the following will apply:

• Your loan application may be registered on your credit report under the name Logbook Money Limited. Should you require more information on any Credit Reference Agency we work with, you can visit the relevant CRA website. We may undertake a search when you apply for credit, thereby reviewing your credit record as well as that of anyone financially associated with you. The agency will keep a record of this search and may place a “footprint” on your file, whether or not the application proceeds.
• Once you take a loan product with us, we will report regularly to the CRAs on your payment history. If you fall behind on payments and satisfactory proposals are not received within a month of a formal demand being issued, then a default notice may be recorded at the CRAs, which may impact your ability to obtain credit in the future.
• Information we and other organisations provide to the CRAs may be used by us and them to:
  • help make decisions when checking applications, managing credit related accounts and facilities, recovering debt, checking on insurance claims, checking job applicants;
  • detect and prevent money laundering, crime and fraud;
  • verify identity;
  • trace your whereabouts;
  • undertake research, statistical analysis and system testing.

Lawful bases

Depending on the activity, we rely on the following lawful bases:

1. Performance of a contract – where processing is necessary to deliver services or meet contractual obligations, including obligations involving TransUnion.
2. Legal obligation – where processing is required to comply with applicable laws, regulatory requirements, or statutory obligations.
3. Legitimate interests – where processing is necessary for legitimate business purposes such as system security, fraud prevention, risk management, audit, and compliance, and where such interests do not override the rights and freedoms of individuals.
4. Consent – where required by law, and where individuals have been provided with a clear choice and the ability to withdraw consent at any time.

Where legitimate interests are relied upon, appropriate assessments are conducted to ensure that the rights and freedoms of data subjects are protected.

Credit Reference and Affordability Checks

To help us assess applications, prevent fraud, and meet our legal and regulatory obligations, we may obtain information about you from credit reference agencies (CRAs).

We obtain this information via Creditsafe, which uses its data partner TransUnion to supply consumer credit and identity data.

1. Creditsafe Business Solutions Limited is authorised and regulated by the Financial Conduct Authority (FCA Firm Reference Number: 7423137)
2. TransUnion International UK Limited is authorised and regulated by the Financial Conduct Authority (FCA Firm Reference Number: 805757)

The information we receive may include data relating to your identity, credit commitments, payment history, and public record information. This data is used solely for legitimate business purposes, including creditworthiness assessment, identity verification, and fraud prevention, in accordance with applicable data protection laws.

Further information about how Creditsafe and TransUnion process your personal data can be found in their respective privacy notices:

1. Creditsafe Privacy / Transparency Notice:
   https://www.creditsafe.com/gb/en/legal/transparency-notice-customer-supplier.html
2. TransUnion CRAIN (Credit Reference Agency Information Notice):
   https://www.transunion.co.uk/legal/privacy-centre/pc-credit-reference
3. TransUnion Bureau Privacy Notice:
   https://www.transunion.co.uk/legal/privacy-centre/pc-bureau

4.0 Information We Share

LBM currently shares your information with:

• agents we instruct to help us collect debts owed to us or to enforce security provided under your agreement where necessary;
• Panel Lenders, to whom we pass your application details;
• credit reference agencies, as described in section 3, and fraud prevention agencies;
• Open Banking service providers, where you choose to give us access to your bank account transaction information, as described in section 7;
• Google and Microsoft, who provide the website analytics (Google Analytics and Microsoft Clarity) and advertising measurement (Google Ads) that we use, but only where you allow the relevant cookies, as described in section 10 and our Cookie Policy;
• regulators, government authorities, our trade association or other authorities to assist in the resolution of a complaint, to help prevent or detect fraud or terrorism, or for any other reasonable purpose identified by such an authority; and/or
• any company or person to whom we sell or transfer our business or our rights under any agreement we may have with you.

We will only ever share your data with third parties for the purposes explained in this policy. All third-party companies we deal with are carefully selected and trusted companies and wherever possible contracts are put in place with them to ensure that your information is kept safe. We will only disclose your information to third parties where such disclosure is permitted by law or where we have your permission.

We may transfer personal data to recipients or service providers located outside the UK and/or European Economic Area (EEA). Where such transfers take place, we ensure appropriate safeguards are in place to protect personal data in accordance with applicable data protection laws. These safeguards may include the use of approved standard contractual clauses, international data transfer agreements, or transfers to countries that have been recognised as providing an adequate level of data protection.

5.0 Personal Data Storage and Security

We know how important it is to keep your data safe, so all information collected is stored on secure servers. Transaction data is encrypted for your safety and we employ up to date security technology to ensure your data remains safe.

You should understand that providing data via online transmission is not always completely secure. We cannot guarantee full protection in this respect, but we do commit that we will do everything we can to protect information sent to us electronically.

Our website may contain links to third parties’ websites, which have their own privacy policies and terms of use. LBM is not responsible, nor do we accept responsibility for third-party websites as we have no control over them.

6.0 Automated Decision Making and Profiling

In some circumstances, we may conduct automated decision making or profiling using personal data. This involves the use of automated systems to evaluate certain information about an individual, such as risk factors, affordability indicators, or fraud signals, based on predefined rules or algorithms.

Where automated decision making is used, it may result in decisions such as the approval, restriction, or rejection of an application or service.

You have the right to request human intervention, to express your point of view, and to challenge decisions made solely by automated means. Further information about automated decision making and how to exercise these rights can be obtained by contacting us using the details provided in this Privacy Policy.

7.0 Customer Bank Account Transactions Information

As part of the application process you may be asked to give LBM access to your bank account transaction information using the Open Banking system.

You may still be allowed to apply for a loan through LBM if you do not provide us with this information. However, if you do, it will help us make an early and informed decision about your application.

If information is not obtained via Open Banking, you are requested to provide your bank account and transaction history using physical copies.

The following provisions shall apply:

• You agree to provide true, accurate, current and complete information about yourself and your bank accounts (with us or third parties) and you agree not to misrepresent your identity or account information. You agree to keep your bank account information up to date, accurate and complete.
• If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies.
• Law enforcement agencies 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;
  • recovering debt;
  • checking details on proposals and claims for all types of insurance; and
  • checking details of job applicants and employees.

We will access your transaction history through a minimum of 60 days’ bank statements provided by you on application. We will use your transaction history to assess your creditworthiness and whether the loan you seek is affordable and suitable.

We will never request, store or have access to your internet banking credentials, PIN codes or passwords.

You understand that allowing us to review your transaction history is at your sole risk.

We cannot guarantee that allowing us to review your transaction history will guarantee the success of your loan application or the rate at which the loan is available.

8.0 Provision of Personal Data

The provision of certain personal data is primarily contractual and, in some circumstances, required to meet legal and regulatory obligations.

Personal data is required to:

• enter into and perform your loan agreement with us;
• process applications and service loans;
• verify identity and prevent fraud; and
• comply with applicable legal, regulatory, accounting, and tax obligations.

If you choose not to provide the personal data, please be aware that:

• we may be unable to enter into a contract with you;
• we may be unable to process your application or service your loan;
• we may be unable to conduct necessary verification, compliance, or fraud prevention checks; and
• as a result, your application may be delayed, restricted, or declined.

Where personal data is requested for optional purposes, such as marketing communications, providing this data is not mandatory, and you may withdraw your consent at any time without affecting the processing of your application or the servicing of your loan.

9.0 The Rights of Data Subjects

Under UK data protection law, you have the following rights in relation to your personal data:

• Right of access – You have the right to request a copy of the personal data we hold about you and information about how it is used.
• Right to rectification – You have the right to request that inaccurate or incomplete personal data is corrected.
• Right to erasure (“right to be forgotten”) – You have the right to request that we delete your personal data where there is no lawful reason for us to continue processing it.
• Right to restrict processing – You have the right to request that we limit how we use your personal data in certain circumstances.
• Right to data portability – You have the right to receive your personal data in a structured, commonly used, and machine readable format, and to request that we transfer it to another organisation where technically feasible.
• Right to object – You have the right to object to the processing of your personal data where we rely on legitimate interests or where data is used for direct marketing.

You have the right to complain to the UK Information Commissioner’s Office (ICO) or another relevant data protection authority if you are dissatisfied with how we manage your personal data.

10.0 Cookie Policy

A cookie is a small text file which is stored on your device when you visit a website. We use cookies and similar technologies in three categories, which you can choose between in the cookie consent manager on our website:

• Necessary cookies: These are needed for our website to work and do not require your consent. They let you complete an online application, keep it secure, remember your cookie choices and, if a partner website sent you to us, record which partner introduced you.
• Analytics cookies (Google Analytics and Microsoft Clarity): These help us understand how visitors use our website, such as which pages they view, how they reached us, where they click and where they have difficulty, so that we can improve it. They are only used if you allow analytics cookies, and Microsoft Clarity is not loaded at all unless you do.
• Advertising cookies (Google Ads): We advertise in Google search results. These cookies let Google Ads tell us when a visit from one of our adverts leads to an application, so that we can measure our advertising. They are only used if you allow advertising cookies. We do not use them to show you personalised adverts or for remarketing.

You can change your choices at any time by selecting the cookie icon at the bottom left of any page of our website. You can also block or delete cookies in your browser settings, but if you block necessary cookies our website will not work as intended and you may not be able to complete an application.

Our Cookie Policy lists each cookie we use, who sets it, what it is for and how long it lasts.

11.0 Accessing Information

The Data Protection Act 2018 and the UK GDPR make provision for you to be able to access any information we may hold on you. This is called a Data Subject Access Request, which you can make by writing to admin@logbookmoney.com

To help us ensure the data we hold about you is accurate and up to date, you may ask us to correct or remove any data that you believe is inaccurate by contacting LBM by writing to admin@logbookmoney.com

When you request information we hold about you, LBM will provide this information to you within 30 days.

You also have the right to request Credit Reference Agencies to provide you with information that they hold about you, but to access such information you must contact them directly.

12.0 Contacting LBM and Opting Out

You can “opt out” of any marketing contact from LBM at any time by contacting us by email, letter or telephone. If you do so, you will not receive any communication other than those relating to your application or account.

You are also able to contact us with queries, requests, or comments on any data issues by contacting LBM.

You can contact us using any of the following methods:

Alternatively, you can use the contact form on the LBM website.

13.0 Data Protection Officer

Logbook Money Limited has appointed a Data Protection Officer (DPO) who is responsible for overseeing our compliance with data protection laws and ensuring that personal data is handled lawfully, fairly, and transparently. If you have any questions about this Privacy Policy, how your personal data is used, or if you wish to exercise any of your data protection rights, you may contact our DPO using the following details: