1. About this notice
This privacy notice applies to the information we hold about you. This privacy notice applies to you if you have applied for our products or if we have received information that relates to you personally. In this notice, 'Abound', 'we' or 'us' mean Fintern Limited, trading as Abound, registered in England No. 12472034. Our registered address is 3rd Floor, 86-90 Paul Street, London, EC2A 4NE. Abound is registered with the Information Commissioner's Office in compliance with the Data Protection (Charges and Information) Regulations 2018 under registration ZA747930. Fintern Limited is authorised and regulated by the Financial Conduct Authority, Firm Reference Number 929244.
Abound is committed to protecting your personal information when you use our products and services. We want you to be confident that your personal information is safe and secure with us and we would like to ensure any offers provided to you are appropriate to your circumstances. When we use your personal information, we are subject to the requirements of the General Data Protection Regulation, also known as "GDPR", which applies across the United Kingdom and the European Union and the Data Protection Act, which applies within the United Kingdom. We are responsible as the 'data controller' of your personal information under those laws.
Please read our notice carefully. It tells you how we collect, use, store and share your information. By using our mobile application and website, you will be regarded as having read and accepted this privacy notice. If you do not wish to be bound by the terms of this privacy notice, you should not use our mobile application or website.
Where we process your personal information, we will ensure that we have a lawful basis to do so. The lawful basis depends on the type processing. The lawful bases which we may apply include to ensure performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract, where the processing is necessary in order to comply with a legal obligation, where the processing is necessary for our legitimate interests or those of a third party, or where you have given clear consent to process your data for a specific purpose
If you choose not to provide personal data for these purposes, it may mean that we cannot perform the services requested or you may not be able to use the products and/or services we offer.
This notice covers data such as information from potential customers who register through our website or on social media, as well as data collection from customers in order to take lending decisions using a mobile App.
2. How we collect data
The way in which we collect and process information about you will depend on how you choose to interact with Abound and what Abound products, if any, you use. We are most likely to receive information about you in the following ways.
- Information when you apply for our product or service
- Information when you use any of our online forms
- Information you provide or we collect when using our mobile application or website
- Information you provide when communicating with us, whether in writing, via email, SMS or by telephone
- Information you provide when completing customer surveys
- Information we obtain if you engage with us on social media, including Facebook and Twitter
- Information when you take part in any promotions
- Information about you provided by third parties such as Credit Reference Agencies.
All your personal data held by Abound is subject to data protection irrespective of the way in which it is communicated or who provides it to us.
3. What type of data do we collect and store?
We will only collect information which is needed in order to provide you with our service about Abound products. This will include information that is used to assess whether our products are affordable for you, to assess our risk in lending to you and to manage your account during the life of your loan. By submitting your personal information to us, you are confirming that the information you are giving is correct and relates to you.
When we seek information from you, it is your choice whether to give it to us. If you choose not to provide some or all of it, your choice may affect our ability to provide you with our products or services.
The personal data we collect will include some or all of the following categories but will extend to any data relating to you that we process as a result of your interactions with Abound:
• Personal Information – your name, date of birth, current and previous addresses, phone numbers, and email address
• Application information – information about your requested loan (e.g. amount requested, monthly repayments, loan purpose) employment, income, residential status, housing costs
• Fraud prevention information – see section 14 below on fraud prevention and detection.
• Bank account information – as part of the process for applying for a loan, and subject to your consent, your bank(s) will provide us with information about your bank account(s) via a process called Open Banking. Open Banking is described in more detail below. This information will include your bank account number, sort code, incomings and outgoings across your bank account(s). Where you have been accepted for an Abound loan, we will use your debit card details to send your loan amount to the account where you receive your main income. We will also set up an arrangement to allow us to collect recurring repayments via a continuous payment authority.
· Credit risk data – information about you provided by credit reference agencies. See section on “Sharing your information” below.
• Communication Information – your contact details and preferred method of contact (whether via letter, email, SMS or telephone),records of emails, telephone calls, letters, texts and webchat between you and Abound.
• Transactional Information – a record of payments made to or received from Abound, details of loan management actions requested.
• User profile – This includes the profile you create to identify yourself when you connect to our mobile applications. It also includes other data about how you use those services. We gather this data from devices you use to connect to those services
• Contractual Information – details about the services and products we may arrange or set up for you
• Documentary Data – details held in documents that are provided to us as part of any application or throughout your relationship with Abound.
• Sensitive or special information – This includes data such as health data, biometric data and criminal records data. See the sections on "Special category data" and "Criminal Offences data" below
• Identification documents – national identifier, a unique number provided by a government body (e.g. a passport number or driving licence number); images of identification documents requested to verify your identity as required by law (e.g. images of driving licence, passport, Biometric Residence Permit)
• Social Media Information - comments made on Facebook, Twitter and discussion forums in connection with our products and services. We may wish to use this information, for example to share a Facebook comment, but we will only do so with your permission
• Operational information – details about the complaints you made to us, your log ins, data subject access requests and any correction requests
• Consents – details of any permissions about data usage that you provide us with, this may relate passing details onto third parties or special data due to medical concerns.
4. How we may use your information
The General Data Protection Regulation states that we are only allowed to use personal information if we have a genuine reason to do so. This includes providing it to third parties outside of Abound.
Abound may use your personal data for one or more reasons including, but not limited to, the following:
4.1 To onboard and serve you as a customer:
· Verify your identity and any other information you've provided us
· Prevent or detect attempted fraud, money laundering or other crime
· Verify your eligibility and suitability for our products and services
· Assess your affordability using Open Banking data, to determine whether you can afford a product you requested or if you can afford to add more to an existing product
· Invite you to register for our services, where you will create a username and password.
· Manage your account(s) with us
· Administer the disbursal of loan funds and the collection of loan repayments
· Send your service messages about your account
· Improve the relevance of marketing messages we may send you
· Use your Transaction Data to make decisions on lending and collecting money from you
· Where you have given us consent to review and monitor your Bank Account(s) and Transaction Data If you make an enquiry of a credit broker that has us on their lending panel, to make a decision whether Abound appears among the lenders shown by the broker and the likelihood of acceptance for a loan to enable you to decide whether you wish to apply for a loan with us.
4.2 To perform our contractual obligations under our agreement with you:
· To respond to your requests, queries and complaints
· To enable you to access our services via our lending platform
· To allow us to provide the services or financing you have requested
· To send you notices required by law e.g. Notices of Sums in Arrears, Notices of Default and Termination letters
4.3 To comply with laws and regulations:
· Complying with your data processing rights
· Prevent or detect fraud, money laundering or other crime
· Regulatory reporting
· Internal and External audit purposes
· UK/EU Data Protection law (GDPR)
· UK/EU anti-money laundering laws and regulations
· UK/EU/UN sanctions (which prohibit us from providing products to certain individuals)
· Rules and regulations imposed by the Financial Conduct Authority and HMRC
· To verify or enforce compliance with the policies governing our products and services and/or applicable laws
4.4 To protect our business:
· To establish, exercise or defend legal claims against us
· To trace and take appropriate action against you should you fail to repay your loan
· To protect against misuse or unauthorised use of our products and services
4.5 To provide you with an enhanced service:
· To provide our support for customers
· To remain in contact with you by email, SMS, post and telephone
· To investigate when you report a problem with our products and service
· To inform you of a new business activity we are undertaking
· To inform you about upgrades to our mobile App
· To ask for your feedback
· Hold any information relating to your physical and mental health you have given us (see Section 5 Special category data).
· Keep you informed of any of our products, services or offers, such as, telling you about new products or launches, and telling you about significant changes to our products. (You can opt out of marketing communications at any time by emailing us or choosing unsubscribe at the bottom of our emails to you. However, there may be some messages that we are required by law or regulation to send you even if you ask us not to.)
4.6 To improve our business and products:
· To help us manage our business better, for example improving our risk models
· Analyse, assess and improve our services to customers, and for training and monitoring purpose
· Prepare statistical reports (including through anonymisation and aggregation of data)
· To conduct research including without limitation: monitoring site usage, understanding visitors' browsing habits, analysing trends and demographic statistics and reviewing individual anonymised usage sessions
· Profile our existing customers to enable us to more accurately identify new customers
5. Special categories of data
5.1 Special Category Data
Special category data is personal data that needs more protection because it is sensitive. There are several sorts of special category defined by the GDPR: the types most likely to be used by Abound are: data concerning health and biometric data used for identification purposes such as images of your face.
We will use special category data for these purposes:
· Identity verification through the use of biometric data
· Ensuring that our services are accessible to you (e.g. if you need extra help because of a disability)We will process special category data only where you have provided us with your explicit consent to do so or if one of the limited reasons for processing applies.
5.2 Criminal Offence Data
Criminal offence data includes information about criminal convictions and offences.
We will use criminal offence data for these purposes:
· Preventing or detecting unlawful acts
We will normally seek your consent to process criminal offence data.
6. Sharing your information
We will keep your information confidential, but we may share it in certain circumstances, where we have a lawful basis to do so, for the purposes set out in this notice with:
· Our service providers and agents
· Anyone we may transfer our rights to
· Regulatory and law enforcement bodies
We'll supply your personal data to credit reference agencies (CRAs) so that they can provide us with supplementary information for the following purposes:
· Verify the accuracy of the information you have provided us
· For use in our affordability and credit risk assessments
· Prevent criminal activity, fraud and money laundering
· Trace and recover debts
· Manage your accounts
· Ensure any offers provided to you are appropriate to your circumstances
CRAs will supply to us both public (including electoral register) and credit, financial situation and financial history information and fraud prevention information about you and also any person that you share financial ties with (a joint current account or a joint mortgage, for example): this person is known as a 'financial associate'.
We use the data to carry out fraud prevention checks and a preliminary credit check which is also known as 'soft credit search' to establish whether you are, or have recently been declared bankrupt, and whether you are currently in a debt management plan or individual voluntary arrangement. The CRAs will record our search but other lenders won't be able to see it and it won't affect your credit score.
However if you decide to formally apply for an Abound loan after carefully reviewing all of our loan documents, including the Pre-Contract Credit Information, Pre-Contractual Adequate Explanations and our Fixed Sum Loan Agreement and Terms and Conditions, we will at time of application, carry out a "Hard Credit Search", which means that when CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.
We'll go on sharing your personal data with CRAs for as long as you are a customer. We will also inform CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. They may also provide this information to other organisations including financial institutions who offer similar products to Abound.
We do not provide joint loans, but if you tell us you have a financial associate (see above), we'll link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging this application. CRAs will 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 a request with the CRAs to break that link.
As a general rule, we'll give you at least 28 days' notice if we decide to file a default on your credit reference file. However, we may not always give you notice beforehand, for example, if we plan to take court action.
The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found in Section 14 of this Privacy Notice or by emailing email@example.com and putting "Request for further details about Fraud Prevention Agencies" in the subject.
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 data, data retention periods and your data protection rights with the CRAs are explained in the Credit Reference Agency Information Notice (CRAIN), which is available from each of the two CRAs-clicking on any of these two links will take you to the CRAIN document:
All Cookies used by the Abound website are used in accordance with current UK and EU Cookie Law.
Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Abound to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
This Website may place the following Cookies:
8. Using other websites
Our websites may contain links to websites which are owned or controlled by parties other than Abound. These links are provided for your convenience and do not imply that we have reviewed or condone the third-party sites, their content or their privacy policies.
When using other websites, you must be aware that any personal information you supply will be dealt with in line with their privacy policies. This Privacy Notice only applies to our website so when you click through to other websites you should read their own privacy policies and terms and conditions before giving them any of your personal information.
Our website and mobile application may also automatically transfer you to a third-party site in order to fulfil the services we provide to you. In such cases, we will carry out due diligence to ensure third parties have the appropriate data protection requirements in place.
When you access linked third-party websites, you do so at your own risk. These sites may place their own cookies or other files on your computer, collect data or solicit personal information from you. We will not be held liable for any misuse of your information or other misconduct by the third party.
9. Where in the world do we send your information?
Abound is based in the UK, and this is where we operate our software platform. Your information will only be used in the UK. Data may be stored in the UK by Abound, or in the UK or EEA by our third parties.
10. Open Banking
Open Banking is a secure way to give us access to your financial information. Implementation of Open Banking in the United Kingdom is overseen by the Open Banking Implementation Entity, set up by the Competition & Markets Authority to bring more competition and innovation to financial services which, in turn, will lead to improved products and customer journeys to help manage your finances.
When you apply for an Abound loan, we will use Open Banking technology for our creditworthiness assessments which will determine the amount of credit you can borrow and the terms of your loan. We ensure any offers provided to you are appropriate to your circumstances.
We will not retain your Internet Banking Credentials. We will only pass your Internet Banking Credentials onto your Bank using an encrypted and secure method of transmission.
11. Automated decision-making of credit decisions
In some instances, our use of your personal information may result in automated decisions being taken. By "automated decisions" we mean decisions made solely by automated means (for example, software algorithms) without any human review.
We use automated decisions to assess your suitability for our products(including their affordability), so that we can determine efficiently and accurately whether to offer you the products you apply for (and therefore whether we can enter into a contract with you) and so that we can perform our obligations under our contract as a responsible lender.
The personal information that we may use as part of any automated decisions includes the information that you (or third parties) provide to us, as described above.
When we make an automated decision about you, you have the right to contest the decision, to express your point of view, and to require a human review of the decision. You will be given the opportunity to request a review within the App or you can exercise your right by emailing us at firstname.lastname@example.org.
12. Your rights
Under the Data Protection legislation, you have the following rights with regards to your personal information:
· The right to be informed about the collection and the use of your personal data
· The right to access personal data and supplementary information
· The right to have inaccurate personal data rectified, or completed if it is incomplete
· The right to erasure (to be forgotten) in certain circumstances
· The right to restrict processing in certain circumstances
· The right to data portability, which allows you to obtain and reuse your personal data for your own purposes across different services
· The right to object to processing in certain circumstances
· Rights in relation to automated decision making and profiling
· The right to withdraw consent at any time (where relevant)
· The right to complain to the Information Commissioner
Please see the following website for more detail:
13. How long will we keep your information?
Unless a longer retention period is required or permitted by law, we will only hold your personal information on our systems for the period necessary to fulfil the purposes outlined in this privacy notice or until you request that the data be deleted.
As a regulated business we are often required to hold personal data for set periods of time. The criteria that we use to determine the period for which we retain personal information include:
· Legal and regulatory requirements and guidance
· Limitation periods that apply in respect of taking legal action
· Our ability to defend ourselves against legal claims and complaints
· Good practice
· The operational requirements of our business
These reasons vary from one piece of information to the next depending on the products and/or services you have signed up for, so the amount of time we keep your personal information for may vary.
· Most customer data will be held for up to 6 years after the end of the relationship
· Contact centre sales call recordings will be held for up to 6 years from the date of the recording
· All other contact centre call recordings will be held for up to 6 years from the date of the recording
· Marketing permissions will be kept and used for up to 6 years after the loan has been paid up or you last access your 'Login' account.
In all cases, our need to use your personal information will be reassessed on a regular basis, and information which is no longer required for any purposes will be disposed of.
If you give us false or inaccurate information or if we suspect or identify fraud, we may record this and may also pass this information to fraud prevention agencies and other organisations involved in crime and fraud prevention including law enforcement agencies.
We and other organisations may access and use this information to prevent fraud, money laundering or other criminal activity.
Fraud prevention agencies may hold your information for different periods of time, and if you are considered to be a fraud or money laundering risk, your information may be held for up to six years. It may also result in us and others refusing to provide services, financing or employment to you.
14. Fair processing notices for the purpose of fraud prevention and detection
Before we provide services, goods or financing to you, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you.
The personal data you have provided, we have collected from you, or we have received from third parties will be used to prevent fraud and money laundering, and to verify your identity.
Details of the personal information that will be processed include, for example: name, address, date of birth, contact details, financial information, employment details, device identifiers including IP address and vehicle details.
We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.
We process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested.
Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.
AUTOMATED DECISIONS OF FRAUD CHECKS
As part of the processing of your personal data, decisions may be made by automated means. This means we may automatically decide that you pose a fraud or money laundering risk if our processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct, or is inconsistent with your previous submissions, or you appear to have deliberately hidden your true identity. You have rights in relation to automated decision making: if you want to know more please contact us using the details above.
CONSEQUENCES OF PROCESSING
If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services or financing you have requested, or to employ you, or we may stop providing existing services to you.
A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details above.
Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to 'international frameworks' intended to enable secure data sharing.
Your personal data is protected by legal rights, which include your rights to object to our processing of your personal data; request that your personal data is erased or corrected; request access to your personal data.
For more information or to exercise your data protection rights, please contact us using the contact details above.
You also have a right to complain to the Information Commissioner's Office which regulates the processing of personal data.
15. Changes to this privacy notice
We can update this Privacy Notice at any time and will keep it under regular review. This privacy notice was updated on 23 SEPT 2022.