About this policy
- We are PeerCredit Ltd trading as PeerCredit (“PeerCredit, we, us, our”). We are a limited company incorporated in England and Wales with registration number 10124494 and our registered office is 1 Canada Square, Canary Wharf, London, United Kingdom, E14 5DY.
- For the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679) (the “Regulation”), the data controller is PeerCredit (“Data Controller”). Contact details for the Data Controller are:
- Our nominated Data Protection Officer for the purposes of the Regulation is Vladimir Repisky who can be contacted by emailing firstname.lastname@example.org.
Information we collect from you
- We will collect and process the following data about you:
This is information about you that you give us when creating an Account on the Platform or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when making use of our Services and when you register on the Platform as a User, whether through creating an Account on the Platform or through creating an Account through an External Profile. We may collect the following Personal Data when you create an Account, use the Platform and/or our Services:
- your first and last name;
- your email address;
- your phone number;
- your usage history on the Platform;
- your preferences for certain kinds of Service;
- if you are making financial transactions via the platform, you may be required to provide a copy of your passport, any other suitable identity document, proof of address, details of your current employment, details of your financials, your bank account information and bank account statements and other income related documents to complete your Risk Profile or to make financial transactions on the platform; and
- any information that you submit when you are using the Platform or Services including without limitation your date of birth and address history.
- This is information we receive about you if you use any of the other Services we provide under PeerCredit. If we receive identifying Personal Data about you, from another third party, then we will notify you of this. The third parties processors with whom we work are listed in Appendix 1.
- We may collect and process certain business data about Users. We confirm that we will not collect or process any Personal Data about any User without their explicit consent.
Personal and Non Personal Data
- As set out above, we collect personally identifiable and non-personally identifiable information about you.
- Personal Data includes information that can identify a user as a specific individual, such as, without limitation, your name, physical address, phone number, credit card number or e-mail address, cookies (defined below), IP logs and other information that is required to process your Account, create your profile or use our services or respond to certain requests (“Personal Data”).
- Non-personally identifiable information (“Non-Personal Data”), is any information that is not Personal Data and which does not, by itself, permit the identification of persons but when linked to a User's Personal Data, can serve to identify that user.
How we collect your data
- Cookies are pieces of code that allow for personalisation of the Platform experience by saving your User information and other preferences. A cookie is a small data file that we transfer to your computer's hard disk for record-keeping purposes. You can delete those cookies by following your browser's instructions but this may change your experience in our Platform requiring you to input all the information again when you re-visit the Platform.
We use the following cookies:
Strictly necessary cookies
These are cookies that are required for the operation of the Platform. They include, for example, cookies that enable you to log into secure areas of the Platform.
They allow us to recognise and count the number of visitors and to see how visitors move around the Platform when they are using it. This helps us to improve the way the Platform works, for example, by ensuring that users are finding what they are looking for easily.
These are used to recognise you when you return to the Platform. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
These cookies record your visit to the Platform, the pages you have visited and the links you have followed. We will use this information to make the Platform and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Other third party cookies
Please be aware that advertisers and other third parties may use their own cookies tags when you click on an advertisement or link on our Platform. These third parties are responsible for setting out their own cookie and privacy policies.
- Strictly necessary cookies
The purpose of the processing of the Personal Data
We will use the information you give to us:
- to create an Account for you;
- to facilitate the provision of our Services to you;
- to carry out our obligations arising from any contracts entered into between you and us (including without limitation to facilitate our underwriting process) and to provide you with the information, products and Services that you request from us;
- to provide you with information about other Services we offer that are similar to those that you have already used or enquired about;
- to keep you up-to-date with new features, products and other Services which we think may be of interest to you;
- to notify you about changes to our Services;
- to ensure that content from our Platform is presented in the most effective manner for you and for your computer.; and
- internal record keeping.
- We may combine the information you give to us and information we collect about you for the purposes set out above (depending on the types of information we receive).
- Where you submit Personal Data for publication on our Platform, we will publish and otherwise use that information in accordance with the Terms and the Applicable Terms.
- To assist us in our marketing, in addition to the data that you provide to us, we may also obtain data from trusted third parties to help us understand what you might be interested in. This ‘profiling’ information is produced from a variety of sources, including publicly available data or from sources such as surveys and polls where you have given your permission for your data to be shared. You have the right to require PeerCredit not to use the information obtained from such third parties. If you wish to exercise this right, you should write to email@example.com and we will apply your preferences going forward.
- We will not, without your express consent, provide your Personal Data to any third parties for the purpose of direct marketing. If you choose to opt-out of direct marketing to which you previously agreed to, you may click the “unsubscribe” button at the bottom of any PeerCredit marketing email or email us at firstname.lastname@example.org.
- We will use the information you give to us:
Managing, Processing and disclosure of your Personal Data
- You can request what Personal Data of yours is collected, processed and stored by us and make any desired changes to such information, by emailing us at email@example.com
- You can also send requests to PeerCredit to update or correct your information. Please email firstname.lastname@example.org with the specific information you would like us to correct or update. We will take all reasonable steps to confirm your identity before we can act on your request.
- You can also delete your Account with PeerCredit by emailing email@example.com . When you delete your Account with us, we delete your User information on the Platform. However, deleting your Account will not always immediately delete the Personal Data you shared with others on the Platform to use the Services (e.g. where you have an outstanding Loan Amount).
- Notwithstanding the provisions of clause 7.3, requests to delete your Account and Personal Data will be subject to any applicable legal and ethical reporting or document filing or retention obligations imposed on us.
We will not process or share your Personal Data with companies, organisations or individuals outside of PeerCredit and any of its subsidiaries from time to time unless;
- you have provided your consent to the processing of your Personal Data (which can be withdrawn at any time). You will have been deemed to have given explicit consent where you tick the appropriate opt-in boxes during the signup process. Before you consent, we aim to name, or clearly describe those third parties to whom we intend to pass your details to;
- the processing is necessary for the performance of the Services;
- the processing is necessary for the performance of a Loan Agreement;
- the processing is necessary for the facilitation of a Friend Loan;
- the processing is necessary for compliance of our legal obligations to which you are subject;
- the processing is necessary in order to protect your interests; and
- for the administration of law and justice, including if in the public interest or required by a Court.
- We will not process any sensitive data (revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data, for the purpose of identifying you, data concerning health or data concerning your sex life or orientation) without your explicit consent for a legitimate purpose.
- We may share your Non Personal Data with third parties such as for analytics of our Platform or advertisers.
Where we store your Personal Data
Security of your Personal Data
As part of our work in securing your data we:
- encrypt your Personal Data;
- are able to restore the availability and access of your Personal Data in a timely manner in the event of a physical or technical incident; and
- complete regular testing, assessing and evaluating of the effectiveness of technical and organisational measures for ensuring the security of the processing.
- Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
How long we store your Personal Data
- We will not keep Personal Data longer than is necessary for the purposes for which they were collected as set out above. If we no longer require your data in order to deliver our Services, such as on deletion of your Account or on termination of the Terms and Applicable Terms by us, we will take all reasonable steps to destroy, or erase from our systems, all of your data as soon as is reasonably possible.
In respect of the Personal Data which we hold, you have:
- the right to be informed about what is happening with your data;
- the right to access your data including confirmation from us if we are processing your data;
- the right to rectify your data if it is inaccurate or incomplete;
- the right to erasure of your Personal Data;
- the right to restrict processing including the right to withdraw consent to the processing of your data;
- the right to reuse your Personal Data for your own purposes across different Services (data portability);
- the right to object to the processing of your Personal Data including direct marketing;
- the right to object to the processing of your Personal Data for automated decision making and profiling;
- the right to request the transfer of your Personal Data; and
- the right to complain as set out below.
- You can exercise the rights at any time by contacting the Data Protection Officer at firstname.lastname@example.org.
- Our Platform may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these websites.
- In respect of the Personal Data which we hold, you have:
Data Access Requests
- You have the right to request a copy of all the Personal Data we hold about you. To do this, write to us at email@example.com. We will take all reasonable steps to confirm your identity before we can act on your request.
- We will endeavor to comply with your request within 30 days from receipt of your request. However if the request is complex or you have made multiple requests, we may take up to 90 days to comply. In such event, we will inform you of this extended time frame within 30 days from receipt of your request.
- Usually, there is no fee payable for a Personal Data request. However, where requests are manifestly unfounded or excessive, or repetitive we may charge a reasonable fee calculated on the administrative cost of providing the information to you. Only in extreme cases will we refuse to respond to a request. Where we decide to do so, we will inform you of such decision, the reason why and of your right to complain to the Information Commissioner’s Office.
- Your copy of the requested information will be presented to you in an electronic document that is clear and easy to understand.
The right to complain
- If you would like to make a complaint to us prior to making a complaint to the Information Commissioner's Office, this can be made in accordance with our Terms and Applicable Terms.
Appendix 1 – List of third parties we may use to conduct identify/credit checks
- SwiftDil Ltd