10 February 2017
We want you to obtain personalised experiences anytime, anywhere, on any device. This requires us to collect personal information from you. However, we want to put you in control of that personal information. We want you to be aware at all times where and how your personal information is being used. This is of paramount importance to us.
So, let’s describe what this Policy tells you. It explains:
what information we may collect about you;
what we may do with the information we collect about you;
whether we share your information with anyone else;
the types of cookies we use and how you can reject these cookies;
where we store your information;
how we keep your information secure; and
your rights in relation to your information.
At Credit Kudos we take your privacy seriously. We operate on the principle that your personal information belongs to you and only you can decide who you want to share it with and why. This is fundamental to the way we work and we’re committed to providing a secure environment for you to store your personal information and share it with others when you want to.
WHEN DOES THIS POLICY APPLY
HERE IS THE INFORMATION WE MAY COLLECT ABOUT YOU
Information you voluntarily provide
If you contact us (by phone, email or through the Platform), we may keep a record of that correspondence for two years in case we need to contact you in relation to the issue for which you contacted us, for operational performance improvement and/or nuisance caller management. We will not use it for marketing purposes.
If you report a problem with the Platform and/or the Services, we may keep that information for two years in case we need to contact you in relation to the issue you for which you contacted us, for operational performance improvement and/or nuisance caller management. We will not use it for marketing purposes.
After registering to use the Platform, you may provide us with credentials to enable us to access your bank and credit card accounts. We do not store these credentials.
We access, copy and otherwise process the transactional data contained within your bank and credit card accounts. We keep that data for two years from your last interaction with the Platform and/or Services.
You should be aware that, depending on the nature of the payors and payees disclosed in your transactional data, we may be made aware of your ethnic origin (e.g. if you have a subscription to The Irish Times), political opinions (e.g., if you pay annual membership fees to a political party), religious or philosophical beliefs (e.g. if you make donations to a place of worship), trade union membership (e.g. if you make subscriptions to a trade union), sex life (e.g. if you have direct debits to certain websites), sexual orientation (e.g. if you pay membership fees to certain organisations) or health (e.g. if you make regular payments to a particular hospital).
The information you give may include your name, address, telephone number, email address, bank and credit card account details as well as passwords and credentials that the bank or credit card provider uses to identify you.
Information we collect about you and your device
When you use the Platform and interact and with our Services, we may use technology such as that provided by Google Analytics to collect information about your visit to our Website. You can find more information about Google Analytics here. In essence, Google Analytics enables us to analyse how you and others interact with our Platform. The information we collect may include:
your IP address;
the type of browser you use (e.g. are you using the Chrome or Safari browser?); and
the number of sessions per browser on each device;
the type of device (eg Samsung) and operating system (eg Android) you are using;
user preferences; and
which pages you visited.
THIS IS WHAT WE DO WITH THE INFORMATION WE COLLECT ABOUT YOU
We use the information you provide to us to:
enable us to provide the Services;
ensure that content from our Platform is presented in the most effective manner for you and for your device to achieve the most user-friendly navigation experience;
provide you with marketing information about us and our services (you may opt out from receiving such information at any time);
notify you about changes to the Platform and the Services;
defend our servers against malicious attacks.
Where we propose using your personal information for any other uses we will ensure that we notify you first. You will also be given the opportunity to withhold or withdraw your consent for the use of your personal information for purposes other than those listed above.
OUR USE OF AGGREGATED AND ANONYMISED INFORMATION
We may provide aggregate user statistics and other usage data which does not identify you specifically with third parties. We may combine your data with those of other users of our Platform and share or provide this information in aggregated and anonymised form with third parties. For example, if we establish that users who obtain their gas and electricity from the same energy retailer are less likely to default on a loan then we may share such information with loan providers, but we would only ever do this with anonymised and aggregated data from which it would be impossible to identify an individual.
We may also use information collected from you and combine it with information provided by other users of our Platform to help us improve the design and delivery of our software tools, increasing the effectiveness for all users.
THIS IS WHO WE SHARE YOUR INFORMATION WITH
We will only share information with other organisations where we have your permission to do so in accordance with this Policy or where we believe it is necessary for a legitimate reason connected with the Platform or our Services.
We work with analytics providers, banks and other credit providers and we may receive information about you from them. We also work with Twitter, Google, Facebook and LinkedIn to allow you to register for the Services using the credentials that you have with those companies. Below is a non-exhaustive list of third parties we work with. We may work with third parties not listed below or stop working with the third parties listed below.
|Name of third party||Why we work with them|
|Google Analytics||To monitor Platform and Website performance & user experience.|
|Various banks and providers of credit||To enable us to provide the Services, including by enabling us to provide transaction data to those banks and providers of credit.|
|Google Apps for Work||To process emails.|
|To allow you to register for the Services using the credentials that you have with this company.|
|To allow you to register for the Services using the credentials that you have with this company.|
In addition, we may disclose your personal information to third parties:
if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request;
to protect the rights, property or safety of our Platform or our users.
Cookies are small pieces of data that are stored on your computer, mobile phone or other device. Pixels are small blocks of code on web pages that do things like allow another server to measure viewing of a Web page and are often used in connection with cookies. HTML5 Local Storage is a small database located inside your browser which web pages can use to store data to speed up their processing. We may use all three technologies from time to time, to help improve your browsing experience.
We have outlined below the individual cookies we use and why we use them:
|Cookie name||Expiry period||Purpose||More information|
|_ga||2 years||Used by Google Analytics to distinguish users.||Google Analytics Cookie Usage|
|_gat||10 minutes||Used by Google Analytics to throttle request rate.||Google Analytics Cookie Usage|
THIS IS WHERE WE STORE YOUR INFORMATION
The data that we collect from you may be processed outside the European Economic Area (EEA) (for example if a bank from which you are applying for a loan needs to seek authorisation from one of its subsidiaries overseas), but we have ensured that there is an adequate level of protection for such data.
KEEPING INFORMATION SECURE
All information you provide to us is stored on servers owned and operated by Amazon Web Services, Inc. More information on this provider is available at https://aws.amazon.com.
HERE ARE YOUR RIGHTS
We think it is important that you are able to control your personal data.
You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing at any time by contacting us at firstname.lastname@example.org.
The law gives you the right to request a copy of the personal information we hold about you. We first require you to prove your identity with 2 pieces of approved identification. We will supply, correct or delete personal information about you on our files. In addition, you may request rectification or erasure of personal information as well as the restriction of processing of your personal information.
If you wish to complain about the processing of your personal information then please contact us first, but if we do not satisfactorily deal with your complaint, then you may contact the Information Commissioner.
If you want to stop using the Platform and the Services, you may do so. If you do, you may also want to remove any cookies that we have placed on any device used to access the Platform and the Services.
THIRD PARTY PROPERTIES ACCESSED FROM THE PLATFORM
Our Platform and Services may contain links to and from the online properties of third parties. If you follow a link to any of these online properties, please note that these online properties have their own privacy policies which will govern use of any personal data that they process. Please check these policies carefully before you click on any links and/or submit any personal data to these online properties.
CHANGE OF CONTROL
If the ownership of our business changes, we may transfer your information to the new owner so they can continue to operate the Platform and provide the Services. The new owner will be obliged to comply with this Policy.
CHANGES TO OUR POLICY
Any changes we may make to this Policy in the future will be posted on this page. Where it makes sense because the changes are material, we will notify you of the changes by e-mail or in another appropriate manner such as when you next interact with the Platform.
CONTACTING US IS EASY AND WE WANT TO HEAR FROM YOU
We really do welcome any questions, comments and requests you may have regarding this Policy. You can contact us by emailing us at email@example.com.