Privacy Policy (June 2017)

We are Oakbrook Finance Limited ("Oakbrook") trading as 'Likely Loans' & ‘Appro Loans’ ("we"). We are committed to protecting and respecting your privacy. This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect will be processed by us. Please read this privacy policy carefully to understand our views and practices and your rights regarding your personal data. By visiting https://likelyloans.com/ and https://approloans.com/(our site) you are accepting and consenting to the practices described in this policy.

For the purpose of the Data Protection Act 1998, the data controller is Oakbrook Finance Limited of The Poynt North, 45 Wollaton Street, Nottingham, United Kingdom, NG1 5FW.

What information do we collect from you?

We will collect and process the following data about you:

  • Information you give us. This is information about you that you give us by filling in forms on our site or by corresponding with us by phone, email or otherwise. It includes information you enter when checking your eligibility for a loan and any subsequent loan application and when setting up your online account with us. Additionally it includes any information you give us for the purposes of entering a competition or promotion, submitting a survey or reporting a problem with our site. The information you give us will include your name, address, email address and phone number, financial information, proof of identification and bank account verification information. During the relationship, including if you get into financial difficulty after taking out a loan with us, we may ask you to provide financial information such as your income and expenditure.
  • Information we collect from your use of our site. With regard to each of your visits to our site we will automatically collect the following information:
    • technical information, such as the Internet protocol (IP) address used to connect your device to the Internet, whereabouts you connected to our service, your internet service provider (ISP), and what type of device you are using to access our service;
    • information about your visit, such as how you interact with our site, how long you spend on each page and the page response times, any error information and your clickstream to, through and from our site. For example, we use services to understand how you and other users navigate around the pages on our site. One such service we use is called Hotjar. Hotjar records how you use our site (e.g. scrolling, clicking) but the data recorded is anonymised. We also use tools like Google Analytics to monitor information such as the clickstream to and from our site, we use tools like Adalyser to monitor the success of our advertising campaigns and we use ecommerce software like iJento.
  • Information we collect throughout our relationship. This is information relating to how you operate and manage your account, including payments made.
  • Information we collect when you call us. If you call our customer service line we will automatically collect the following information:
    • the phone number used to call our customer service number
    • a recording of all inbound and outbound calls.
  • 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 Hotjar and Google Analytics mentioned above, 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 ‘How is your information kept secure?’ section below.
  • Online Account Information. This is information we may gather through your online account with us. It relates to the way you use our site and your online account, such as the pages you navigate to, time and duration of logins, where you click and your anonymous feedback given in the ‘help us improve’ sidebar which may appear during your visit to our site.

Why do we collect this information?

We use this information in the following ways:

  • Information you give to us. We use this information:
    • in order to take steps necessary to assess whether we can enter into a contract with you and, if your application is successful, in order to perform our contract with you. This includes processing your applications, assessing eligibility for loans, credit and fraud checks, managing your account, carrying out our obligations to you and providing you with our products and services;
    • for the purpose of improving our service to you, to ensure that content from our site is presented in the most effective manner for you and for your device;
    • to deal with any legal queries relating to your use of our service;
    • to provide you with service communications so that you receive a full and functional service and so we can perform our obligations to you. These may be sent by email, post, WhatsApp, text or, if the circumstances require it, we may contact you by phone. These will include notifications about changes to our service and information about the services you are using, including payment reminders sent by text message and answers to frequently asked questions by other customers;
    • to provide you with marketing communications including:
      • information about other goods and services we offer that are similar to those that you have already purchased or enquired about, including additional borrowing and products you may be eligible to apply for, including Top up and pre-approved loans.;
      • with your permission, selected third parties will provide you, with information about goods or services they feel may interest you. If you do not want us to pass your details on to third parties for marketing purposes, please leave the relevant box blank.
    • If you are declined for a loan then we may also present you with the option to authorise us to pass your data to a third party who will check to see if another loan provider may be able to offer you a loan. If you choose to authorise this, we will pass on your information to these third parties.
  • Information we collect from your use of the site. We will use this information for the following purposes:
    • 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 collect throughout our relationship. We will use the information to help us manage your account, make improvements, and for credit reference and fraud purposes. See the ‘Who might we share your information with?’ section below for further information on how data is shared with credit reference and fraud protection agencies.
  • Information we receive from other sources. See the ‘Who might we share your information with?’ section below for details of how we use information in conjunction with our associated third parties.
  • Social Connect. During the application process you have the option to use Social Connect to link selected social media profiles to your loan application. This allows us to pull information from your social media profiles into your application, speeding up the process. To do this we use tools like ‘Hello Soda’. If you choose to use this social connect service then we may use this data in decision making as set out under ‘Bank Checking’ below.
  • Bank checking. We may use tools to check bank data and build a profile of you in order to evaluate your eligibility for a loan. We may use these tools to help us decide whether we can offer you a loan, the affordability of the loan, to prove your identity, for fraud prevention and, in the future, these might help us to inform you of the impact of your borrowing on your financial circumstances.

Who might we share your information with?

You agree that for the purposes set out in the ‘Why do we collect this information?’ section above, we have the right to share your personal information with:

  • Selected associated third parties, some of whom we appoint to provide services, including:
    • our payment provider in order to process your payments;
    • business partners, subsidiaries, suppliers and sub-contractors for the performance of any contract we enter into with you;
    • analytics and search engine providers that assist us in the improvement and optimisation of our site;
    • credit reference agencies for the purpose of assessing your credit score;
    • Customer survey providers in order to receive feedback and improve our services.
  • Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
Additionally, we will disclose your personal information to the relevant third party:
  • In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
  • If we are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of our customers, Oakbrook, our regulator, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection, prevention of money laundering and credit risk reduction.
  • Credit reference and fraud protection agencies. In order to fulfil the service we provide to you we will share your information with credit reference agencies. The credit reference agencies will not store, retain or use your information other than to fulfil the service. Your use of the service, will not be visible to other lenders, and will not affect your ability to obtain credit in the future. In order to prevent or detect fraud, the information provided by you will be checked with and recorded by a fraud prevention agencies, if false of inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies to prevent fraud and money laundering. If you go on to apply for one of our loans, you will be provided with further information about how your information will be used and shared in order to process your application and how the information held by fraud prevention agencies may be used; alternatively you can obtain this information by calling us on 0208 080 6450 or by writing to us at The Poynt North, 45 Wollaton Street, Nottingham, NG1 5FW.

  • Debt collection agencies. In some circumstances, if you take out a loan with us and enter financial difficulties, we may pass your information to debt collection agencies.

How is your data stored and kept secure?

At Likely Loans, we make your safety and security our top priority and we are committed to protecting your personal and financial information. All information kept by us is stored on our secure servers. We hold a certification under the UK Government Cyber Essentials Plus scheme. Any payment transactions will be handled by our third party payment provider and encrypted. We will never store your credit or debit card details ourselves.

Payment Provider Details:

  • Payments Place, a trading name of TDX Group Limited, Capital House, 25 Chapel Street, London, United Kingdom NW1 5DS
  • TALKINGTECH UK Ltd, 1 Adam Street, London, UNITED KINGDOM, WC2N 6LE
  • 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.

  • The online communications platform which we use to send out our customer emails is located in the USA and is covered by Privacy Shield. Data in or attached to these emails will be processed outside the EEA. It may also be processed by staff operating outside the EEA who work for our provider. By submitting your personal data, you agree to this processing. We will take all steps reasonably necessary to ensure that your data is treated securely in line with this privacy policy.

  • Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

What are your rights?

You have the right to ask us not to process your personal data, or pass it to our associated third parties, for marketing purposes.

You can exercise your right to opt-out of marketing at any time by using the unsubscribe options included in the marketing communication or by contacting us using the contact information below. If you do not give us consent to process your data for marketing purposes you may miss out on special promotions or services which you may be interested in.

The Regulator. Should you have any issues, concerns or problems in relation to your data, or wish to notify us of data which is inaccurate, please let us know by writing to us at privacy@likelyloans.com . If you are not satisfied with the processing of your data you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) which is the supervisory authority for data protection in the UK. We request that you first bring any complaint to our attention before contacting the ICO so that we may take appropriate action to resolve the issue.

Accessing your personal information. You have the right to a copy of the information we hold about you. You may make an access request by writing to Likely Loans, The Poynt North, 45 Wollaton Street, Nottingham, NG1 5FW, contacting privacy@likelyloans.com, or calling 0208 080 6450. Any access request will be processed as required by law, and will be free of charge.

Links

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. These websites have their own privacy policies and we do not accept any responsibility for these sites. Please check their policies before you submit any personal data to these sites.

Changes to our privacy policy

This policy may be updated from time to time. Please check back frequently to see any updates or changes to our privacy policy.

Contact us

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Oakbrook Finance, The Poynt North, 45 Wollaton Street, Nottingham, NG1 5FW or privacy@likelyloans.com or you can call us on 0208 080 6450.

Our website uses cookies so we can tell you apart from other users of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve it.

A cookie is a small file of letters and numbers that we store on your browser or device if you agree. Cookies allow a website to recognise a particular device or browser during a visit and if you visit our site again later on.

We use the following types of cookies:

  • Strictly necessary cookies. These are cookies that are, quite simply, strictly necessary for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our site, use our loan eligibility checker or make secure payments.
    If you disable these cookies then parts of our site will no longer work for you. It also limits our ability to keep your information secure, such as when you apply for a loan.
  • Performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. We also use third party performance cookies to record and analyse information of this nature in order for us to improve our website. Two examples are highlighted below but other cookies may be used to carry out similar functions.
    • Google Analytics
      We use Google Analytics to help us collect and assess this information. Google Analytics stores information such as what pages you visit, how long you are on the site, how you got here and what you click on. The information is anonymous and cannot be used to identify you. To opt out of Google Analytics cookies please visit their webpage at https://tools.google.com/dlpage/gaoptout
    • Hotjar analytics
      We use a service called Hotjar to understand how you and other users navigate around the pages on our site, the data recorded for this is anonymous. You can find further information on how Hotjar uses cookies here: https://docs.hotjar.com/v1.0/docs/hotjar-cookies
      To opt out of Hotjar cookies please visit their webpage at https://www.hotjar.com/opt-out
  • Functionality cookies. These are used to recognise you when you return to our site. This enables us to personalise our content for you, remember your username, and remember if you are resuming an application you started previously. If you are an online account user then we’ll use a cookie to remember that and we may show you more information that is relevant to you as a result.
  • Targeting cookies. These cookies record your visit to our site, the pages you have visited and the links you have followed. We will use this information to make our site and our advertising more relevant to your interests. For example, targeting cookies may help us to improve the targeting of our advertising by excluding people who have recently applied for a loan with us from seeing our adverts or by identifying audiences who are more likely to be interested in our adverts. We provide third party advertisers such as Google with this information so our adverts can be placed on third party websites. If you choose to block these cookies you will still see our adverts on other websites but they will not be tailored to you.
  • Managing Your Cookies
    You can block cookies by activating the setting on your browser that allows you to refuse all or some cookies. You can also use browser settings to remove cookies from your device. You can find out how to do this on your browser’s website, but these settings are normally easy to find in the privacy section of your browser settings. For mobile devices try looking in the browser app settings. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

We may send you marketing materials by post. If you do not wish to receive these, you can opt out at any time by phoning us on 0208 080 6450, emailing us at loans@likelyloans.com or by writing to us at Oakbrook Finance, The Poynt North, 45 Wollaton Street, Nottingham, NG1 5FW.