myfreedom, Fusion Score and Freedom Finance are trading styles of Freedom Finance Limited. We are authorised and regulated by the Financial Conduct Authority (FRN: 662079).
Our registered office is Freedom Finance Ltd, Atlantic House, Atlas Business Park, Simonsway, Manchester, M22 5PR. Registered in England: 06297533. Our Data Protection Register number is Z120757X.
Freedom Finance Limited will be the data controller for the data that you provide us with or we collect in relation to the provision of our Services to you (as defined in our myfreedom terms and conditions)
The information we collect
Information you give us. You may give us information about you when you use our services and when you communicate with us. This includes information you input during registration by answering specific questions on our site, applying for a loan or credit card, receiving advice on ways to repay your debts, providing us with feedback, participating in surveys, and when you can you report a problem.
Personal data collected, used, stored and transferred by us may include:
- Your name and identity data, including forenames, last name, maiden name, date of birth, gender, marital status or similar identifier).
- Contact data including home address, email address, telephone number and your residential status.
- Employment status.
- Financial information (including bank statements, payment card details, savings, debts such as loans and credit cards, income & expenditure, employer & pension benefits, and other assets)
- Technical Data including internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices used to access the Freedom Finance Ltd website.
- Your banking provider(s).
- Monthly expenditure.
- Insurance products you hold.
- Family and dependents.
- Your aspirations (e.g. to buy a car).
- Personal information or documents required to identify you.
- Profile and Usage Data including feedback and survey responses, and how you use our website, products and services.
- Marketing and Communications Data including your preferences in receiving marketing from us and our business partners and your communication preferences.
- Special Category Data such as medical or health conditions may only be collected with your explicit consent.
Information that we may receive from your bank. You have the option to link your myfreedom Service with your bank, in which case your bank may share with us information about you which could include:
- Your bank account type and details
- Account number and sort code
- Account balance
- Bank account transactions (incoming and outgoing)
- Card transactions (incoming and outgoing)
- The fees, charges and interest you pay
- The benefits, services, rewards and interest your account offers
Special categories of data. The categorisation of some of your transactions may include special categories of data as it may be indicative of your political beliefs (e.g., if you pay for membership for a political party).
Information we collect about you. We will collect information during your use of the myfreedom Services including: (a) the details regarding the communications made between us; (b) technical information including the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; (c) information about your visit (including date and time); (d) products you viewed or searched for; (e) page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
Recording telephone calls and other communications. We may monitor or record telephone conversations or other communications between you and us. These may be used for staff training and monitoring purposes.
How do we collect your personal data?
Personal data is collected by us using the following methods:
- Direct contact with our staff by phone, email, webchat, post or otherwise for example; for the purpose of applying for & processing loans, confirming identity, handling complaints etc.
- Automated technologies or interactions with our website, by using the web enquiry form or the find a loan function for the purpose of; processing identity, loan application etc.
- Third parties or publicly available sources such as credit reference agencies, Lenders, couriers, third party & partner websites.
- Open Banking and data collection from your nominated bank account.
How we use the information
We will use the information we hold about you to provide our myfreedom Service to you and improve our services, administer your account and communicate with you and to use information on an anonymous basis for research, profiling and analytical purposes.
Information you give us, or we collect from other third parties. We will use this information to:
- Provide you with information, products and services.
- Analysing and reporting on your account and transaction data that we obtain from your bank.
- Verify your identity as part of our identity authentication process.
- Notify you about changes to our services.
- Ensure that content on our site is presented in the most effective manner for you and your device.
- Aggregate it on an anonymous basis with other data for data analytical and reporting purposes.
- To ensure compliance with your requests for the exercise of your rights.
- To manage our communications in relation to your queries or complaints.
Information we collect about you based on your use of our site. We will use this information to:
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- To improve the services we provide to you.
- Continually improve our ability to keep our products safe and secure and to prevent fraud.
Data analytics. We will use the information we hold about you to conduct analysis of it for the following purposes:
- Analysis of information about you on a personalised or aggregated basis to further tailor the experience to you.
- Verify the accuracy of data that we hold about you and create a better understanding of you as a myfreedom customer.
- To provide you with a better service by conducting statistical analysis and system testing to understand your needs.
- Network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access.
What we will never do. we will never sell your information to third parties.
Information we receive from other sources. We may combine this information with information you give to us and use this information and the combined information for the purposes set out above.
Recording telephone calls and other communications. We will use telephone recordings or transcripts of communications to check your instructions to us, analyse, assess and improve our services, for training and quality purposes and for the purposes of investigating any complaint you may make, or as evidence in any dispute between you and us.
Who may we share your data with?
We may share your data with lenders or service providers who you ask us to provide an eligibility quotation. Occasionally we may share your data with other third parties, such as a lender you select, a debt management company or Insolvency Practitioner if you select that service, other service providers, Credit Reference Agencies and Fraud Prevention Agencies.
We may need to disclose your data to others to ensure the smooth provision to you of our Services and any information you request. Your data may be disclosed to the other entities as described below.
Service Providers: We may share your information with the following providers:
- Equifax (Credit Reference Agency) – https://www.equifax.co.uk/About-us/Privacy_policy.html?advsrcSuggest=FFW
- Experian (Credit Reference Agency) – https://www.experian.co.uk/consumer/privacy.html
- consents.online (Account Information Services Provider) – https://consents.online/Privacy
- Aryza UK Services Limited (provider of the software we use to provide advice on clearing your debts) – https://www.aryza.com/privacy-policy-2/
Group company. We may share your personal information with any member of our group, which means our Freedom Finance Group companies for accounting, statistical and analytical purposes. Freedom Finance Group consists of Freedom Finance & Freedom 365 Mortgage Solutions. Freedom Mortgages and Mortgage Advice Bureau are trading names of Freedom 365 Mortgage Solutions Limited, who are Appointed Representatives of Mortgage Advice Bureau Limited.
Selected third parties. We may also share your information with selected third parties including:
- Credit Reference Agencies (“CRAs”): if you use our Services we will obtain on your behalf, in accordance with our Terms and Conditions, copies of your credit report and credit score from designated CRAs. In order to provide these services to you, we will share your information with such CRAs. The information which we provide to the CRAs may be supplied by them to other organisations such as Fraud Prevention Agencies and used by those organisations for the purposes of checking identity, preventing fraud, tracing and collection of debt. The CRAs may also use the data to undertake statistical analysis. If you choose to apply for a product, the lender will undertake a full credit check and provide you with further privacy information for that product.
- TransUnion – Under data protection laws we are permitted to share some information where the reason for doing so is legitimate and isn’t outweighed by the effects it will have on the relevant individuals. On that basis we may pass your data to TransUnion (https://www.callcredit.co.uk/legal-information/bureau-privacy-notice?advsrcSuggest=FFW) who may combine it with data from other sources, analyse and profile it (such as by predicting information about you), and pass their knowledge on to other companies to help trace you to provide important information or return assets to you. Your data may also be used in a similar manner to aid debt recovery and to prevent fraud by helping to identify you (for instance when you are applying for new products). TransUnion may also provide your data to other organisations to support the assessment of credit risk, pricing and affordable payments. If you do not wish for your data to be used this way by TransUnion then please contact us at email@example.com
- FCA regulated lenders (for example, to source and submit an application for loans, credit cards or mortgage products).
- Other credit brokers (if we are unable to service your request for a loan, credit card, or mortgage product).
- Debt-solutions providers such as Insolvency Practitioners (if you choose to take-advantage of our debt-advisory process).
- Solicitors & Surveyors (for example, to check the progress of your application with whom you are interacting).
- External suppliers – We may also share information with external supplier’s specialist IT system providers to facilitate the sourcing of products, to provide continuing advice, to inform you about relevant products and services, and to request feedback on customer service standards and to store data. It may also be necessary to share your personal information with non-affiliated companies who perform support services on our behalf including those that provide professional, legal or accounting advice to Freedom Finance Ltd.
- Analytics and search engine providers that assist us in the improvement and optimisation of our service. We may use third party advertising platform providers such as Google to serve advertisements to you. These third parties may use information about your visits to this and other websites in order to provide you with advertising about products and services that may be of interest to you.
- Regulators – Sharing of information may be necessary with the Regulators to fulfil our legal obligations as a regulated profession, for example with the Financial Conduct Authority or the Information Commissioner’s Office. Sharing of information to verify your identity and comply with Anti Money Laundering legislation, and otherwise co-operate with law enforcement, legal proceedings or regulatory authorities.
- Others – If a third party introduced you to Freedom Finance, we may pass some of your personal information back to that third party so they know whether or not you took out a mortgage, credit agreement, debt solutions product or other service through us.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.
- Your data will be treated confidentially and these companies are required to ensure appropriate security measures are in place and maintain the confidentiality of your personal data, and to use your personal data only in the course of providing such services and in accordance with Freedom Finance Ltd instructions.
- If we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets or the buyer or seller’s advisers
- If we or part or all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; and
- 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 myfreedom Terms and other agreements; or to protect the rights, property, or safety of Freedom Finance Limited, our customers, or others.
What is the legal basis for us using this information?
We make sure we have appropriate legal bases on which to collect, use and share data about you. If you have any questions about the lawful bases on which we collect and use your personal data, you can contact our Director of Risk & Compliance.
Our lawful bases may include consent (where you have given consent), performance of a contract (where processing is necessary for the performance of a contract with you (such as delivering our core services to you), compliance with our legal obligations and our own legitimate interests.
- Consent. We will always seek your consent to process certain types of information where we are legally required to do so. You have the right to withdraw or decline your consent at any time. We use consent to initially engage with you to discuss your requirements including to confirm in which form we may communicate with you and re-engage, for example, when an existing product nears expiry.
- Performance of a Contract. To process and deliver your application for a loan, to offer you a recommendation to manage any outstanding debts you have, to manage our relationship with you & improve our customer service such as customer reviews / surveys. We need you to give us the information you provide, and to collect information about you from the Credit Reference Agencies and your Account Providers, in order for us to provide you with our services as agreed in our contract with you. If you do not give us this information, we will not be able to provide our services to you.
- Compliance with our legal obligations, to respond to enquiries and complaints, for example.
- Legitimate Interests. We may process your personal data for the purposes of our own legitimate interests or for the legitimate interests of our suppliers provided that such processing does not outweigh your interests. As an example, we may process your personal data to:
- Comply with our legal obligations;
- Keep our records up to date;
- Provide you with our services, including for the purpose of quality control and analysis;
- Develop and improve our products and services;
- Communicating and managing our relationship with you;
- Deliver relevant website and advertisement content to you;
- Administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
- Measure or understand the effectiveness of the advertising we serve to you
- Use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
When we rely on our legitimate interests for processing your data, you have the right to object at any time.
How long we keep your information for
How long we keep your information will depend on the purpose for which we use it, our obligations and your actions. We will only retain your information in an un-anonymised format for as long as is necessary for those purposes.
Where we receive your bank account information from Account Providers, we will retain it in the following manner:
- If you actively opt to revoke your consent we will immediately erase all your bank account information
- If you continue to have a myfreedom account we will retain your bank information for no more than 7 years from the date of the original consent
We will keep your personal information for as long as you are a user of the myfreedom Service. We may keep your personal information for up to 7 years after it is no longer required to provide you with the myfreedom Service. We do this:
- To enable us to respond to a question or complaint or to demonstrate we gave you fair treatment
- To study data as part of our own internal research;
- To obey rules that apply to us about record keeping.
We may also keep your data for longer than 7 years if we cannot delete it for legal, regulatory or technical reasons.
After termination of your account, we may continue to use anonymised data (which does not identify individual users) which is aggregated with anonymised data of other customers. We use this aggregated anonymised data for data analysis, profiling and research purposes, for example to gain insights about our users. We may also keep your email address to ensure that you no longer receive any communications from us.
Where do we store and process your personal data
We are committed to safeguarding your information and use industry standard methods to ensure that all the information you provide is secure. We store this on secure servers so that it can only be viewed by authorised personnel. We will only collect personally identifiable information to the extent deemed reasonably necessary to serve our legitimate business purposes. If we do transfer it outside the EEA, the information may be processed by staff operating outside the EEA who work for us or one or more suppliers. Such staff may be engaged in, among other things, the fulfilment of services, the processing of the application details, and the provision of support services.
How we protect your information
All information you provide to us is stored on our secure servers.
We do our best to protect your personal data, but we cannot guarantee the security of your data transmitted to our app; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access, loss or damage.
We only process your information within the UK and European Economic Area (EEA).
How long is personal data retained?
We only retain your personal data for as long as necessary, i.e. for our regulatory requirements or our legal obligation. The table below outlines how long data is retained, and depends on the reason the personal data is used for.
|Purpose of processing||How long will we keep your information for?|
|Successful mortgage / loan / credit card applications and applications for debt products such as an IVA or debt management plan.||Records will be retained indefinitely. Information that does not need to be accessed regularly after 6 years, but which still needs to be retained, will be safely archived.|
|Withdrawn, incomplete and failed mortgage / loan / credit card applications and applications for debt products such as an IVA or debt management plan.||2 years from the date the latest application began.|
|Enquiry data obtained from you or from third parties that do not result in an application for any of the products or services available from us.||2 years from the date the lead was received from the Introducer|
|Data provided by you or third parties in connection with the myfreedom and Fusion Score services.||Records will be retained indefinitely. Information that does not need to be accessed regularly after 6 years, but which still needs to be retained, will be safely archived.|
|Future marketing of customer data – where consent has been given to keep customers informed of other products and services within the Freedom Finance Group that may be of interest.||Indefinitely unless you withdraw your consent and/or requests data be removed.|
After these retention periods, if there is no other on-going relationship, your personal data will either be securely deleted or anonymised so that it can be used for statistical purposes but without any method of identifying you individually.
How myfreedom uses your data
The Fusion Score
The Fusion Score uses Open Banking to provide you with a complete view of your eligibility for credit. It does this by aggregating your Equifax Credit Report with insights from your bank transactions. For example: the money you have coming in each month, the money you typically have left each month, and how much you pay towards your rent, subscriptions and bills. As a result, you can better understand your financial situation.
We do this as a result of our partnership with Consents.online Limited who are authorised by the Financial Conduct Authority as an Account Information Service Provider to provide Open Banking services.
Open Banking is a UK initiative to give regulated third party providers such as Consents.online access to consumers’ financial accounts providing a consumer has given explicit consent for this to happen. Consents.online has appointed Freedom Finance as its agent and Freedom Finance has had this status approved by the Financial Conduct Authority: https://register.fca.org.uk/s/firm?id=0014G00002VoZzEQAV&advsrcSuggest=FFW
- Your bank/building society will then verify your identity so that they can be certain you have securely shared your information with Consents.online and authorised it to have access to your account.
- Once this verification is complete, your bank/building society will provide Consents.online with 12 months’ history of your banking transactions. Consents.online will share this with Freedom Finance.
Freedom Finance use the information provided to us via Consents.online in the following ways:
- To calculate your Fusion Score. To do this, we use the categorised transactional information to analyse your income and expenditure. This enables us to: calculate what you can afford to borrow, exactly as a lender would. To grant you credit a lender is required by law to perform an ‘affordability check’ to work out how much money you could have left over at the end of each month if you were to borrow from them. Unlike a credit score your Fusion Score covers affordability as well as your credit history, which we get from your Equifax credit report.
- To generate your positive and negative factors. This provides you with positive, neutral, and negative factors which are based on both the data we receive from Consents.online and Equifax.
- To pre-populate an application form you may elect to complete whilst using our service.
- To ‘enhance your offers’ during an eligibility search for a credit product. Some of our partners have products, special rates or pre-approvals that are only available to customers who share their bank transaction data with them when requesting a quote. Examples of Lenders who we might encrypt and onward-share your data with for this purpose are:
- My Community Finance
- Oakbrook Ltd
- Leap Lending
- Capital One
The following communications are essential parts of delivering your myfreedom account and cannot be opted-out of:
- To send you a welcome email when you first create your account
- To notify you that you are yet to connect your bank
- We will email you reminders that your myfreedom account remains open no more than once every 90 days
- We will email you a copy of the results from any searches you may complete from your myfreedom account and reminders of when quotes expire
You can exercise specific rights with regards to the data that we hold about you.
We will provide you with the necessary tools and contact details to be able to exercise your statutory rights regarding the information that we hold about you. You will be able to:
- Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. You have the right to request copies of all records we hold about you.
- Request correction of the personal data. This enables you to have any incomplete or inaccurate data corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete personal data where there is no reason for us continuing to process it or where you have successfully objected to the processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please note that we may not always be able to delete the data for specific legal reasons, if applicable we will notify you, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
For the exercise of any of your rights, you can also contact us at: firstname.lastname@example.org
We keep our Privacy Notice under regular review and may change it without notice.
Please also refer to our Terms & Conditions which outlines the service we provide.
You will also have the choice to opt-in to receiving other related marketing information and related products and services. Both we and other carefully selected organisations or alternative credit and insurance providers may contact you by telephone, letter, e-mail, SMS or other social media to offer other credit or insurance products which may be of interest to you. We may also send you information about money saving tips and guides. You can opt-out of receiving these types of communications at any time by contacting us at email@example.com or by clicking on the relevant link in email communications you receive from us.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal data to only those Freedom Finance staff, appointed representatives, advisers, business partners and suppliers who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
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- storing your preferences and settings, which can be recalled when you re-visit a website
- delivering interactive services and completing applications
- maintaining online security and helping to protect against online fraud
- analysing how our products perform, tracking website performance, conducting research and diagnostics, and fulfilling other legitimate purposes to give you a better online experience
- storing and sharing your browser activity so that our advertising partners may provide content on products relevant to your interests
- helping us to understand how people use our website – for example, if lots of people give up on an application process at a particular step, we can try to make that step easier to use
* Please note that our cookies do not store any personal or confidential information about you
Be aware that if you choose to disable or delete cookies relating to our website, the following may occur:
- we will not be able to recall information about you, including your preferences, and you will be treated as a first-time visitor
- some of our online services might not work as you may expect
- as you browse from page to page relevant information may have to be entered more than once
To find out more about cookies, visit www.allaboutcookies.org.
THIRD PARTY’S COOKIES
Cookies served by Equifax are held on Freedom Finance’s website. Equifax is a consumer credit reporting agency. These cookies will be used to serve adverts to visitors based upon the websites they’ve been to previously.
Click here for more information about Equifax and how to disable this cookie.
Freedom Finance Ltd website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
If you follow a link to or from our app to a third-party website, please be aware that these websites have their own privacy policies.
Our Service 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 also refer to our Terms & Conditions for more information
If you have any questions or complaints relating to how we use your personal data, or if you wish to exercise any of your rights regarding your personal data, you may request this by writing to the Compliance Department Freedom Finance Ltd, Atlantic House, Atlas Business Park, Simonsway, Manchester, M22 5PR or emailing firstname.lastname@example.org
We shall respond to your request as soon as possible, depending on the complexity of the request but no later than one month from receiving it. If we need additional time, we will tell you and give you the reasons why.
If you are not satisfied with how we respond to your enquiry, you have the right to complain to the Information Commissioner’s Office (ICO), who is the regulator for data protection in the United Kingdom.
You may also have the right to refer any complaint you make to the Financial Ombudsman Service (FOS), which is an independent arbitration service and helps settle disputes between customers and businesses.
Your right to lodge a complaint with the ICO
If you are not satisfied with our response to any complaints you raise with us or you believe our processing of your information does not comply with the data protection law, we suggest you contact us in the first instance. However, you can make a complaint to the Information Commissioner’s Office (ICO) at any time.
Please see the ICO website for further information – https://ico.org.uk/make-a-complaint?advsrcSuggest=FFW/