Privacy Policy

Published on: 23/05/2018

1. General

1.1 Welcome to choosewisely.co.uk and thank You for taking the time to read Our Privacy Policy. Please read it carefully before using Our Website, because by continuing to use it, You are agreeing to be bound by its terms.

1.2 We take Your privacy and the security of Your personal data seriously. We’ll always do Our best to ensure that Your data is collected lawfully, stored safely, transported securely and processed responsibly. We comply with relevant data protection legislation and We’re registered with the Information Commissioner’s Office.

1.3 If You have any queries relating to Our use of Your personal information, or any other related data protection questions, please contact the Choose Wisely team at [email protected]

1.4 From time to time, We may change or update this Privacy Policy. If We do, the updated or amended Privacy Policy will be posted to this page.

1.5 If any provision of this Privacy Policy is held to be unlawful, invalid or unenforceable, that provision shall be deemed deleted, and the validity and enforceability of the remaining provisions shall not be affected.

1.6 This Privacy Policy, together with Our Terms & Conditions and Cookie Policy , constitute the entire agreement between You and Us relating to Your access to and use of choosewisely.co.uk and supersede any prior agreements.

1.7 No failure or delay by Us in exercising any right under this Privacy Policy will operate as a waiver of that right nor will any single or partial exercise by Us of any right preclude any further exercise of any right.

1.8 This Privacy Policy shall be governed and interpreted in all respects, in accordance with the laws of England and Wales.

2. Overview

2.1 On choosewisely.co.uk, You can access a number of Tools aimed at helping You understand and identify suitable credit and banking Products. Many of these Tools feature forms that You can use to register, to tell Us about yourself, and to tell Us about the Products that You’re interested in. These forms collect contact details, information about Your personal circumstances, and/or information about Your financial background.

2.2 We collect this information to enable You to access and use the Tools featured on the Website and without it, some Tools and other features may not work at all. We also collect information to understand and give You feedback on Your financial situation, to tailor the results displayed on comparison tables, to make the site more relevant for You, to help speed-up form-filling, to ensure that You only see Products that match Your requirements, and to communicate with You about the services You’ve accessed.

2.3 We collect information about how You use the site - information such as which pages You view, how long You spend reading different pages and which parts of the site You click on. The Choose Wisely team uses this kind of information to understand how good a job choosewisely.co.uk is doing, to identify ways that We can make the Website better and to understand the impact of any changes We make.

2.4 When You visit choosewisely.co.uk, the Website will attempt to leave tiny text files on Your device called “Cookies”. We use Cookies for a number of reasons. Some cookies identify who You are so that We can remember Your settings, some ensure that You have a consistent, personalised experience each time You visit, and others enable Us to carry out research, to analyse market trends and to monitor how successful the Website is.

2.5 Some features on choosewisely.co.uk are aimed at helping You gain an understanding of how eligible You are for certain Products or if certain Providers will accept You if You are to make an application. In these instances, the Website may share Your personal data with Providers so that they can make an accurate assessment, identify You and respond accordingly.

2.6 We may share information about You with other members of Our group of companies, with service Providers who enable Us to host and monitor Our Website, and with regulatory or governmental bodies.

3. About Us

3.1 choosewisely.co.uk and Choose Wisely are trading names of Choose Wisely Limited. Choose Wisely Limited is the data controller. Choose Wisely Limited is registered with the Information Commissioner’s Office (Registration Number Z3106681).

3.2 Where data is passed to a Provider as part of Your application journey or through Your use of a Tool that features on choosewisely.co.uk, the Provider may also be acting as a data controller and/or a data processor. You should read your chosen Provider’s privacy policy before applying.

3.3 Our Data Protection Officer is Choose Wisely’s Chief Executive Officer. To contact Our Data Protection Officer please email [email protected] or write to Choose Wisely, Telephone House, 18 Christchurch Road, Bournemouth BH1 3NE.

4. Definitions

In this Privacy Policy:

Product

means any third party bank account, business loan, credit card, personal loan, or prepaid debit card displayed on Our Website;

Provider

means a financial services Provider supplying one or more Products;

Quote

means a price relating to a Product provided by a Provider for comparison with other Quotes, on the basis of the information You have provided;

Tools

means interactive features of choosewisely.co.uk including the Budget Planner, comparison tables, ClearChoice, the Eligibility Checker, the Loan Calculator,

the Money for the Many email signup at the foot of each page, Our Product pages, the Simple Loan Search, and

Our WiseGuides;

We, Us and Our

means choosewisely.co.uk or Choose Wisely or belonging to choosewisely.co.uk or Choose Wisely, both trading styles of Choose Wisely Limited;

Website

means pages, Tools and content available at choosewisely.co.uk; and

You, Your, Yourself

means You, belonging to You, or about You personally, the user of Our Website.

5. Your rights

5.1 As part of data protection law, You have certain rights. They are as follows:

5.1.2 the right to be informed - to have access to all the information contained within this policy;

5.1.3 The right of access - to request a copy of the information We hold about You;

5.1.4 the right of rectification - to insist that We amend any of the data We hold about You if it is inaccurate or incomplete;

5.1.5 the right to be forgotten - to insist that We delete or put the information We hold about You beyond use;

5.1.6 the right to restrict - to stop Us using Your personal information or limit the way We can use it;

5.1.7 the right of data portability - the right to request that We move, copy or transfer Your personal information to someone else who does the same thing that We do;

5.1.8 the right to object - to object to Our use of Your personal information including where We use it for Our legitimate interests or where We use Your personal information to carry out profiling to inform Our market research and customer demographics.

5.2 To make enquiries, exercise any of Your rights set out in this Privacy Policy or to make a complaint, please email the Choose Wisely team at [email protected] If You are not satisfied with the way any complaint You make in relation to Your personal information is handled by Us then You may be able to refer Your complaint to the Information Commissioner’s Office.

6. How We collect Your personal information

6.1 We may collect personal information from You through the online data entry forms that are a component part of Tools and features of choosewisely.co.uk.

6.1 We may collect personal information from You as You navigate and use the Website.

6.2 We may also collect personal information about You from other websites if you were referred to choosewisely.co.uk by a third party.

7. The personal information that We collect

7.1 When You register to use any of the Tools that feature on Our Website, We may collect personal information including:

7.1.2 information about the Product(s) You’re searching for;

7.1.3 Your name;

7.1.4 Your address;

7.1.5 Your email address;

7.1.6 Your telephone number;

7.1.7 information about Your home;

7.1.8 information about Your employment;

7.1.9 information about Your income and expenditure;

7.1.10 information about Your financial circumstances; and

7.1.11 and which bank You use.

7.2 We may collect personal information including your name, email and IP address during the course of leaving a review about a Product or Provider.

7.3 We may collect personal information including your name, email and IP address during the course of providing feedback on the operation of our website or your experience whilst using it.

7.4 We may collect any personal information you provide us with whilst communicating with the Choose Wisely team via email, post, SMS, telephone or any other means.

7.5 Whilst You visit Our Website, We may collect information about how You came to or how You use Our Website. For example We might collect information about the pages You view, how long You spend or information about how You found choosewisely.co.uk in the first place.

7.6 We do not collect any personal information that data protection legislation defines as “sensitive personal information”.

7.7 If You are using choosewisely.co.uk on behalf of someone else, please ensure that they first read this policy along with Our Terms & Conditions before You proceed. By giving Us information about another person You are confirming that they have given You consent to provide their information to Us and that they understand how their details will be used.

7.8 We will take all reasonable measures to ensure the security and safety of Your information and will periodically review it to ensure that We don’t keep it longer than is necessary.

8. How long We keep Your personal information for

8.1 We retain the personal information we collect from You only for as long as is necessary for the purpose for which it was collected. In most cases, we will keep Your personal information while You're a regular user of Our Website, and for seven years thereafter. In other cases we'll store personal information for the periods needed for the purposes for which the information was collected or for which it is to be further processed. And sometimes we'll keep it for longer if we need to by law.

8.2 At the end of the retention period, Your personal information will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

9. How We use Your personal information

9.1 We may use Your personal information in the following way:

9.1.1 to enable You to access and use the Budget Planner, Our comparison tables, ClearChoice, the Eligibility Checker, the Loan Calculator, Our Product pages, the Simple Loan Search, and Our WiseGuides;

9.1.2 to personalise and improve Your experience of using choosewisely.co.uk and improve the experience for future users;

9.1.3 for research purposes, such as analysing market trends, understanding customer demographics, and gaining insight into consumer behaviour;

9.1.4 to send You confirmation of Your Quote, results and/or notifications of actions You need to take as a result of Your use of one of the Tools featured on choosewisely.co.uk. When You obtain a Quote with Us, You will automatically be sent a series of communications for Your records and to prompt You to take action where necessary. This function forms part of how Our Tools operate and by using one or more of Our Tools, You agree to receive these communications;

9.1.5 to communicate with You about Your financial circumstances and how to improve Your financial situation. If You agree, We may contact You (depending on the preferences You select) via email, post, telephone, or sms;

9.1.6 to communicate with You about Products and services which We think may be of interest to You. If You agree, We may contact You (depending on the preferences You select) via email, post, telephone, or sms;

9.1.7 to communicate with You to provide renewal Quotes when Our systems indicate that Your renewal is due or You are eligible. If You agree, We may contact You (depending on the preferences You select) via email, post, telephone, or sms;

9.1.8 to search websites and interrogate software systems belonging to Providers in order to obtain the best Quotes available to You, to check Your eligibility, or to check Your likelihood of acceptance with them;

9.1.9 to track sales, which may involve Us sharing data with Your chosen Provider relating to the Product You have purchased. Your chosen Provider may also send Us information they hold relating to any Product You take out for this purpose; and

9.1.10 to match Our data with data from other sources (such as double-checking Your postcode) to ensure that the data We hold is accurate, organised and up to date.

9.2 We will store the personal information You provide and may use it to pre-populate fields on choosewisely.co.uk to make it easier for You to use Our Tools when You return for another visit. If You do not want Us to store and use Your personal information in this way, You can disable cookies for Our Website. Please be aware that the site may not function as intended if You decide to disable cookies.

9.3 We may monitor and record Your calls, emails, sms, and other communications for business purposes, in accordance with data protection legislation and any other applicable law.

9.4 In some instances, Our use of Your personal information may result in automated decisions being taken.

9.5 Automated decisions mean that a decision concerning You is made automatically on the basis of a computer determination (using software algorithms, machine learning and/or artificial intelligence), without being reviewed by a human. For example, We may use automated decisions:

9.5.1 to assess Your creditworthiness;

9.5.2 to assess Your eligibility for a certain Product or Products;

9.5.3 to assess Your likelihood of being accepted for a certain Product or Products; and

9.5.4 to verify Your identity when We process your application for a certain Product or Products.

9.6 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 can exercise this right by emailing the Choose Wisely team at [email protected]

10. How We process Your personal information

10.1 Data protection legislation sets out a number of different reasons for which a company may collect and process Your personal data. Our legal basis for collecting and using Your personal information will depend on the personal information concerned and the specific context in which we collect it, including:

10.2 Consent. Where necessary, We will collect and process Your personal information if You give Your consent for Us to do so. An example of this is Our marketing communications. We will only communicate with You about Products and services that We think may be of interest to You if We have Your consent to do so.

10.3 Contractual necessity. In certain circumstances, We need Your personal information to comply with Our contractual obligations. For example, if We contract to provide You with a renewal reminder when the interest-free balance transfer period expires on Your credit card, We'll need to collect Your name, contact details and details about that credit card in order to provide you with the service.

10.4 Legal compliance. If the law requires Us to, We may need to collect and process Your data. For example, We may be called upon to share information of people involved in fraud to law enforcement agencies.

10.5 Legitimate interest. In terms of the operation of the Tools featured on choosewisely.co.uk, We collect and process Your personal information because We have sensible and legitimate reasons for doing so - specifically because by using Our Tools, You’re asking Us to do so and without Your personal information, they simply couldn’t function. Our legitimate interests for processing Your personal information are:

10.5.1 to enable the Tools featured on choosewisely.co.uk to function by providing analysis of Your financial circumstances, searching Provider’s websites to retrieve accurate Quotes, interrogating Provider’s software systems to assess eligibility likelihood of acceptance, and tracking eventual successful completions. The Tools simply would not work for You if they did not collect and process Your personal information in this way;

10.5.2 to enable the Tools featured on choosewisely.co.uk to communicate with You (this doesn’t include marketing communications unless You have given Us Your consent to receive these); and

10.5.3 to improve the Tools featured on choosewisely.co.uk. We may use Your personal information to personalise aspects of the function Our Tools or for market research and analysis purposes. The Choose Wisely team constantly works to improve the experience provided on choosewisely.co.uk and using Your personal information in this way helps Us to do this.

11. Who We share Your personal information with

11.1 When We collect personal information from You, We may disclose it to the following parties:

11.1.1 other companies within Our group. Choose Wisely Limited is owned by the Ratio International Trading Company Limited. The Ratio International Trading Company Limited employs the Choose Wisely team, a limited number of whom may access your personal data from time to time in order to do their jobs. Choose Wisely team members are trained and regularly refreshed in how to conduct themselves properly in respect of personal data;

11.1.2 Providers. Specifically the companies whose Products or services feature on choosewisely.co.uk. We share Your personal information with Providers to enable them to provide You with a Quote, and to understand Your eligibility or likelihood of acceptance with them. Providers with whom we share Your personal information may use it for their legitimate business interests to match applications, carry out fraud checks, carry out research such as analysis of market trends and customer demographics and to customise and develop the product/service which they offer to you or other individuals in the future. Providers might use your personal data for these purposes for up to 12 months. When these companies use Your personal information in this way, they will be acting as data controllers and You should ensure that You read Your chosen Provider's Privacy Policy. You can see a full list of the Providers who feature on Our Website here;

11.1.3 credit brokers. Some Providers whose Products feature on Our Website use third party credit brokers to process applications on their behalf;

11.1.4 regulatory bodies. Where and when We are required to do so, We provide market insight to the Financial Conduct Authority and the Competition & Markets Authority;

11.1.5 service Providers. We may disclose Your personal information to service Providers who help Us with things like Website hosting, email sending and performance analysis. If You would like a full list of these service Providers, please contact Our Data Protection Officer; and

11.1.6 where required, We may also disclose information about You:

11.1.6.1 if required or permitted by law;

11.1.6.2 if required to do so by any court, applicable regulatory body, government or law enforcement agency;

11.1.6.3 if necessary in connection with legal proceedings or potential legal proceedings; and/or

11.1.6.4 in connection with the sale or potential sale of all or part of Our business.

11.2 Some Providers will use Your personal information to assess Your circumstances and verify the information that You have provided before providing a Quote to You. Some Providers may carry out checks with fraud prevention and credit reference agencies, both at initial Quote stage and at the point of any subsequent renewal. If Providers do these checks, they will likely be visible to other organisations. Both public data (e.g. the electoral roll) and private data (e.g. Your personal credit history) may be checked in this way.

11.3 If You decide to enter into a contract with a Provider through choosewisely.co.uk, the information You provide Us will be held by the Provider for the purposes set out in their privacy policy. Please ensure that You read Your chosen Provider's privacy policy to satisfy Yourself as to the purposes for which the Provider will use Your personal information before entering into any contract with them. We have no responsibility for the uses to which a Provider puts Your personal information.

12. How we keep Your information secure

12.1 We use appropriate technical and organisational measures to protect the personal information that We collect and process about You. The measures We use are designed to provide a level or security appropriate to the risk of processing Your personal information.

12.2 We follow our security procedures and apply suitable technical measures, such as encryption and use of Secure Sockets Layer technology, to protect Your information.

12.3 Specific measures We use include:

12.3.1 Implementation of best practice security principles within Our infrastructure (e.g. use of firewalls and a DMZ);

12.3.2 adopting security safeguards against attacks (e.g. internal and external monitoring of network traffic use, and carrying out regular tests); and

12.3.3 security policies that provide working guidelines to the Choose Wisely team and the enforcement of controls and procedures in line with data protection legislation and other financial services industry-specific compliance requirements.

13. International data transfers

13.1 Our technical infrastructure is located within the European Economic Area (EEA).

13.2 From time to time, Your personal information may be transferred to, and processed outside of the EEA. These countries may have data protection legislation that is different to the legislation that applies to the EEA (and, in some cases, may not be as protective).

13.2 Specifically, whilst We operate predominantly in the United Kingdom, some Providers operate around the world. This means that when We collect your personal information and share it with a Provider, they may collect, store and/or process it outside of the EEA.

13.4 Where this is the case, We have taken appropriate measures to ensure that personal information remains protected in accordance with this Privacy Policy.

14. Cookies

Cookies are tiny text files placed onto the device You use to browse Our Website. We use cookies for a number of reasons. Some cookies identify who You are so that We can remember Your settings, some ensure that You have a consistent and personalised experience each time You visit, and others enable Us to carry out research, to analyse market trends and to monitor how successful the Website is. For more information on the cookies We use, please see Our Cookie Policy .

15. Implementation of Policy

This Policy shall be deemed effective as of 23/05/2018. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.