LOANPAD PRIVACY POLICY

Introduction

This is our privacy policy. It tells you how we collect and process personal data received from you on our site and via electronic communications. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

If you have any comments on this privacy policy, please email them to dpo@loanpad.com.

What we do

Here are the details that the Data Protection Act 2018 (DPA 2018) on the protection of natural persons with regards to the processing of personal data and on the free movement of such data, known as the UK General Data Protection Regulation (UK GDPR) says we have to give you as a 'data controller':

• Our site address is www.loanpad.com
• Our company name is Loanpad Limited
• Our registered address is 5 Technology Park, Colindeep Lane, Colindale, London, NW9 6BX
• Our Data Protection Officer can be contacted at dpo@loanpad.com

What we may collect

We may collect and process the following data about you:

• Information you put into forms (including information provided as part of the account opening process) or surveys on our site at any time;
• A record of any correspondence between us;
• Details of transactions you carry out through our site;
• Details of your visits to our site and the resources you use; and
• Information about your computer (e.g. your IP address, browser, operating system, etc.) for system administration and to report aggregate information to our advertisers.

We may also collect, store and use the following "special categories" of more sensitive personal information:

• Information about your race or ethnicity and religious beliefs;
• Information about your health, including any medical condition, health and sickness records;
• Biometric data; and
• Information about criminal convictions and offences.

Under UK GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:

1. you have given consent to the processing of your personal data for one or more specific purposes;
2. processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
3. processing is necessary for compliance with a legal obligation to which we are subject;
4. processing is necessary to protect the vital interests of you or of another natural person;
5. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
6. processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our credit card payment processing, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

Cookies

We use cookies to distinguish users and improve our site. Please look at our Cookies Policy - www.loanpad.com/cookies-policy - for more information.

How we use what we collect

We use information about you to:

• Present site content effectively to you;
• Provide information, products and services that you request, or (with your consent) which we think may interest you;
• Carry out our contracts with you and to establish and administer your Platform Account(s);
• To notify you of any changes to our services or products;
• Allow you to use our interactive services if you want to;
• Tell you our charges; and / or
• Tell you about other goods and services that might interest you.

We will only contact you electronically about updates and changes in relation to your account and loans, unless you agree to be contacted for other marketing purposes by ticking the relevant boxes that you will find during registration.

If you don't want to be contacted for marketing purposes, please tick the relevant boxes that you may find during registration or use the ‘unsubscribe’ feature in our electronic communications to opt out if you have already opted in.

Please note: We don't identify individuals to our advertisers, but we do give them aggregate information to help them reach their target audience, and we may use information we have collected to display advertisements to that audience.

In addition, if you don’t want us to use your personal data for any of the other reasons set out in this section, you can let us know at any time by contacting us at dpo@loanpad.com and, where there are no statutory, contractual or other requirements to keep your data, we will delete your data from our systems. However, you acknowledge that in order to prevent fraud or other financial crime, record keeping requirements require us to keep your information for at least six years from the date we close your account.

How we use particularly sensitive personal information

"Special categories" of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the situations below:

• In limited circumstances, with your clear written consent;
• Where we need to carry out our legal obligations and in line with our data protection policy or other policy that applies to such information; and / or
• Where it is needed in the public interest, such as for equal opportunities monitoring, and in line with our data protection policy or other policy that applies to such information.

Very occasionally, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

Our obligations

We will use your particularly sensitive personal information in order to prevent fraud or other financial crime.

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will give you full details of the information that we would like and the reason we need it, so that you can consider carefully whether you wish to consent.

Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy or other policy that applies to such information.

Very occasionally, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

We envisage that we will hold information about criminal convictions.

Where we store your data

We may transfer your collected data to storage outside the UK.

By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.

If we give you a password, you must keep it confidential. Please don't share it. Although we try to provide protection, we cannot guarantee complete security for your data, and you take the risk that any sending of that data turns out to be not secure despite our efforts.

We only keep your personal data for as long as we need to in order to use it as described above, and/or for as long as we have your permission to keep it, and/or for as long as there are statutory or contractual requirements to keep it.

Once our relationship with you has ended we will retain information that allows us to:

• Comply with record-keeping requirements under law or regulation (for example, as required under the Money Laundering Regulations);
• Deal appropriately with any complaints regarding the services we have provided;
• Defend (or potentially bring) any existing or future legal claims; and / or
• Maintain records of anyone who does not want to receive marketing from us to prevent us from inadvertently ignoring your wishes in the future.

If we do retain your information for lawful reasons we will continue to ensure that your privacy is protected. In any event, we will conduct an annual review to ascertain whether we need to keep your personal data. Your personal data will be deleted if we no longer need it.

Disclosing your information

We are allowed to disclose your information in the following cases:

• If we want to sell our business, or our company, we can disclose it to the potential buyer;
• We can disclose it to other businesses in our group; and
• We can disclose it if we have a legal obligation to do so, or in order to protect other people's property, safety or rights.

We can exchange information with others to protect against fraud or credit risks.

We may contract with third parties to supply services to you on our behalf. We will not disclose your data to any third parties (unless required to for any regulatory or legal reasons) without first obtaining your consent.

Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under UK GDPR and the law.

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Your rights

You can ask us not to use your data for marketing. You can do this by ticking the relevant boxes on our forms, or by contacting us at any time at dpo@loanpad.com.

Under the UK GDPR, you have the right to:

• request access to, deletion of or correction of, your personal data held by us at no cost to you;
• request that your personal data be transferred to another person (data portability);
• be informed of what data processing is taking place;
• restrict processing;
• to object to processing of your personal data; and
• complain to a supervisory authority.

You also have rights with respect to automated decision-making and profiling as set out below.

To enforce any of the foregoing rights or if you have any other questions about our site or this Privacy Policy, please contact us at dpo@loanpad.com.

Links to other sites

Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from our site. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

Changes

If we change our Privacy Policy, we will post the changes on this page. If we decide to, we may also notify you via email or the Loanpad Platform.

Automated Decision-Making and Profiling

In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge such decisions under UK GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us.

The right described above does not apply in the following circumstances:

1. the decision is necessary for the entry into, or performance of, a contract between the you and us;
2. the decision is authorised by law; or;
3. you have given you explicit consent.

Where we use your personal data for profiling purposes, the following shall apply:

1. Clear information explaining the profiling will be provided, including its significance and the likely consequences;
2. Appropriate mathematical or statistical procedures will be used;
3. Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
4. All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

Complaints

If you want to make a complaint about Loanpad or how we have handled your personal data, you can email us at complaints@loanpad.com with brief details of your complaint and your Loanpad account number. For full details of our complaints procedure, please visit www.loanpad.com/complaints-policy.

In the unlikely event that we are unable to resolve your complaint, you may also be able to refer the complaint to the Information Commissioner’s Office (ICO), details of which can be found at www.ico.org.uk. You can also do this without first complaining to us.

Any complaint or dispute shall not affect the parties’ ongoing obligations under this Privacy Policy.

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