Privacy Policy (August 2018)

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 when you visit https://likelyloans.com/ and https://approloans.com/(our site) or when you use our services.

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:

  • Full name and personal details including contact information such as your home address and address history, email address, home and mobile telephone numbers.
  • Your Date of Birth.
  • Financial information – such as your income and expenditure which is used to enable us to make a decision regarding your eligibility and affordability for a loan with us. Additional information on your income and expenditure may be required throughout the duration of the loan in order to ensure your repayments remain affordable.
  • Proof of identification.
  • Bank account details.
  • Throughout our relationship we will collect information relating to how you operate and manage your account including payments made.
  • 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.
  • Any other information you provide to us directly.

How do we use the information we collect from you?

To enter into and perform our obligations under a contract with you:

  • 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.
  • To deal with any legal queries relating to your use of our service.
  • To maintain business and service continuity.
  • To provide you with service communications so that you receive a full and functional service and so we can perform our obligations to you, for example to send you an annual statement. These service communications 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.

Where we have your consent:

  • If we are unable to provide you with a loan, with your consent, we will pass your data to a third party who will assess the information you have provided against their panel of providers to see if another lender may be able to offer you a loan. At the point at which you need to consent to this you will be provided with a link to see how they will use your data.

For your legitimate interests or those of other persons and organisations:

  • To provide you with marketing communications by email and SMS where you have not opted out of us doing so 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 loans. You can unsubscribe from receiving marketing materials by e-mail and SMS at any time by using the unsubscribe links in each communication or by contacting us as detailed below.
  • We may send you marketing materials by post. If you do not wish to receive these, you can object to receiving these at any time by phoning us on 0208 080 6450, visiting our contact page or by writing to us at Oakbrook Finance, The Poynt North, 45 Wollaton Street, Nottingham, NG1 5FW. We will cease sending marketing communication to you by post upon receipt of you raising an objection.
  • To defend against or exercise legal claims and to deal with complaints.

To comply with legal requirements relating to:

  • the provision of products and services;
  • data protection;
  • health and safety;
  • anti-money laundering;
  • fraud investigations;
  • assisting law enforcement; and
  • any other legal obligations placed on us from time to time.
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 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.
  • For the purposes of monitoring the success of any advertising campaigns we use tools like Adalyser.
  • Information we may gather through your use of 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.

How do we use information collected about you when you use our site?

To enter into and perform our obligations under a contract with you:

  • 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.
  • For fraud identification and prevention.
  • If you apply for a loan information regarding your use of our site is used as part of our automated decision making process.

In our legitimate interests of providing the best service and improving and growing our business we will process information in order to:

  • Measure or understand the effectiveness of advertising we serve to you and others to deliver relevant advertising to you.
  • Improve our site to ensure that content is presented in the most effective manner for you and for your device.
  • To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
  • 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 comply with legal requirements

  • For fraud identification and prevention.
Information we receive about you from other sources

We receive information about you from other sources such as:

  • Credit Reference and Fraud Prevention agencies. The information they provide us with may include electoral roll information, payment details and outstanding balances for other accounts, details of any County Court Judgements and your credit rating.
  • Your current bank or building society. In certain circumstances we may ask for permission to obtain transactional data about you from your bank. Your consent will always be required for this prior to us obtaining this information. This service is provided by Consents Online.
  • Payment providers who will supply us with information about Debit or Credit Card payments you make towards your loan.
  • Tracking information regarding e-mail delivery, open rates and click through rates.
Information we exchange with third parties

For the purposes set out above about how and why we collect information about you, we will exchange your personal information:

To enter into and perform our obligations under a contract with you:

  • Credit Reference Agencies – We will perform credit and identity checks with one or more Credit Reference Agencies. We will supply them with your data and they will give us data about you. When you obtain a quote from us we carry out a search, this is called a quotation search and is not visible to other lenders. If you proceed with your application and a full search is undertaken this will be visible to other lenders. We will continue to exchange information about you with the Credit Reference Agencies for the duration of our relationship. This will include details on how you manage your account, the balance outstanding and whether your payments are made on time or not. We will use this information when considering whether to offer you further borrowing for example Top Up loans. Further information about how information is exchanged with Credit Reference Agencies can be found in the Credit Reference Agency Information Notice (CRAIN) which can be accessed via:
  • Fraud Prevention Agencies – We will perform checks and share your personal information with fraud prevention agencies to verify your identity and to prevent fraud and money laundering. In order to prevent or detect fraud, the information provided by you will be checked with and recorded by Fraud prevention agencies, if false or inaccurate information is provided and fraud is identified you could be refused certain services, finance or employment. 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.
  • Your current bank or building society – Where you consent to your bank or building society providing us with information about your account we will use this information to help us build a profile of you in order to assess your eligibility for a loan, verify your identity and assess your affordability.
  • Payment Providers – we will use information received about you from our payment providers in money laundering prevention and to allocate your payments to your account. 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.
    • 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
    • Stripe Payments UK, 1 Bath Place, London, EC2A 3QB
  • Debt Collection Agencies - In some circumstances, if you default on your loan with us we may pass your information to Debt Collection Agencies to collect payments on your account on our behalf.
  • Any member of our group - which means our subsidiaries, our ultimate holding company and its subsidiaries. This includes BC India whom we outsource various administrative tasks to, for example changing payment dates. This will involve them having access to your personal data. Please see the Transfer of Data Outside the EEA section below for information about measures used to secure your personal data as part of this arrangement.
  • Legal and professional advisors including our auditors.
  • Funders whom we have an obligation to report to.
  • 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.
  • Customer survey providers in order to receive feedback and improve our services.

For your legitimate interests or those of other persons and organisations:

  • Information we obtain about you from Credit Reference Agencies, any transactional data received from your bank and building society and the information we already hold will be used for profiling and used to inform our future lending criteria.
  • We will also retain information received from third parties to defend or exercise legal claims and to deal with complaints.

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 us about our 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, for example to the Financial Conduct Authority, the Information Commissioner’s Office, the Financial Ombudsman Service or HMRC.
  • 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 prevention, prevention of money laundering and credit risk reduction.
Automated decision making

We use automated decision making as part of our loan assessment process. We use an internal scorecard which takes the data you provide us with and combines it with information from Credit Reference Agencies (this will include details on how you manage your accounts, the balances outstanding and whether your payments are made on time or not). From that information an automated decision is taken on whether to lend based on our pre-defined criteria. Additionally, if we do lend we would continue to run this scoring to decide whether to invite you to apply for a top up loan.

How long is your data stored for and how is it kept secure?

At Oakbrook Finance, we are committed to protecting your personal and financial information. Once we have received your information, we use strict procedures and security features to prevent unauthorised access.

All information kept by us is stored on our secure servers. We hold a certification under the UK Government Cyber Essentials Plus scheme. 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.

If you become a customer we will process your data for no longer than 12 months following your loan being repaid in full, if any processing takes place after this time your data will be pseudonymised prior to the processing taking place. With the following exception: your data will be retained for 10 years from the date of your loan being repaid in full, in order for us to respond to claims, unless we determine that there is reasonable justification for retaining records for a longer period due to developments around known claims in the industry.

If you do not become a customer we will retain your data for 12 months in order to answer any queries you may raise and to keep our lending policy under review after this time your data will be pseudonymised.

If we have reason to suspect fraud we will retain the necessary data to enable us to comply with anti-money laundering regulations.

Transfer of data outside the EEA

For the fulfilment of some of our services to you we transfer some data outside of the European Economic Area (“EEA”). Where we transfer data outside of the EEA we have ensured that adequate protection is in place and appropriate safeguards are applied. Please see below for more details:

  • The online communications platform which we use to send 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.
  • Credit Reference Agencies may share information with their head offices which are based outside of the EEA.
  • Our Online Account Services provider is based outside of the EEA in the USA, however our customer information in relation to an account is hosted on servers within the EU. In the event of any incidents related to the provision of this service, the information required to resolve service issues may be shared with personnel outside of the EEA.
  • Some of our fraud prevention tool providers are based in the USA. Information shared with these providers consists of your IP address, location data and device information.
  • We supply information to our funders who are based in the USA. The information supplied consists of your postcode, age and transactional data.
  • We outsource some administrative tasks to a wholly owned subsidiary of our Parent Company. The Company we use is BC India, they are based in India. In order to carry out administrative tasks on our behalf they have access to our systems.

We use safeguards such as Commission approved model clauses, Privacy Shield Certifications and other safeguards when transferring personal data outside the EEA. For more information or to obtain a copy of these safeguards, please contact us as set out at the end of this Policy.

What are your rights?
  • The right to be informed about the processing of your personal data. This policy contains the information about how and why we process your data. If you require any additional information you can contact us using the contact details on our website.
  • The right to have your personal data corrected if it is inaccurate and to have incomplete personal data completed. It’s important that the information we hold about you is correct. Please contact us at the earliest opportunity if we hold information that you believe to be inaccurate.
  • The right to object to the processing of your personal data. Where we have relied on legitimate interests to process your data you have the right to ask us to stop. Where processing of the data is necessary for the performance of the contract this will not be possible.
  • The right to restrict the processing of your personal data. You have the right to request the restriction or suppression of your data. This will only apply in certain circumstances. Where processing is restricted we are permitted to store the personal data but not use it.
  • The right to be forgotten. You have the right to request us to delete information we hold about you. Where this is not possible we will explain why.
  • The right to request access to your personal data and information about how we process it. You have the right to request 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 within one month, and will be free of charge.
  • The right to move, copy or transfer your personal data (data portability) Data portability allows you to request and reuse your data for your own purposes across different services.
  • Rights in relation to automated decision making including profiling. Where we have used automated decision making you have the right to request human intervention or challenge the decision.

You have the right to withdraw consent where you have previously given it, for example for the purposes of marketing communication via Email and SMS. You have the right to ask us not to process your personal data 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 updating your Marketing Preferences in the ‘My details’ section in your online account. Additionally you can contact us by using our contact details on our website. If you do not give us consent to contact you via Email and SMS for marketing purposes you may miss out on special promotions or services which you may be interested in.

You would need to opt out of receiving postal marketing separately.

Complaints

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 prior to contacting the ICO so that we may take appropriate action to resolve the issue.

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.

Information about our use of cookies

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, check your eligibility for a loan 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 which 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 https://tools.google.com/dlpage/gaoptout.
    • Hotjar 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 parties such as Google and Facebook 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.
    We use Experian to make the content and advertising shown on devices that you might use or that may relate to the same household more relevant and useful. As part of this process Experian uses cookies and may receive information about the kind of device you use as well as your IP address, location data, device user agent string or information about websites where your device has previously displayed advertising. By using the Likely Loans site, you consent to the processing of data about you by Experian for the above purpose and for the profiling of audiences bearing similarities to your data. You have a choice about whether or not you want your information to be used in this way and you can set your preferences by visiting www.experianmarketingservices.digital/cookieoptout. This won’t stop you from seeing content about our products and services when you visit our website, but it will mean that the content you do see may not be as relevant to you.
  • Managing Your Cookies. Cookies can be controlled by your web browser settings. Whether our cookies are used will depend on your browser settings, so you are in control. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please use the following links:

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.

For the purpose of the General Data Protection Regulation the data controller is Oakbrook Finance Limited.