Privacy Notice & Cookies
HALIFAX CREDIT CHECKER
Date adopted: 07/01/2018
- Who we are and how you can contact us
- What we use personal data for
- What kinds of personal data we use, and where we get it from
- What our legal grounds for handling personal data are
- Who we share the personal data with
- Where the personal data is stored and sent
- How long the personal data is kept for
- Whether the personal data is used to make decisions about you or to profile you
- Your rights in relation to the personal data we hold about you
- Who you can complain to if you are unhappy about the use of your personal data
- What cookies are used on the website
WHO WE ARE AND HOW YOU CAN CONTACT US
We are TransUnion Information Group (TU UK), which is a group of companies with headquarters at One Park Lane, Leeds, West Yorkshire LS3 1EP. Some of the members of TU UK are listed in section 5 below.
The company which operates this website is Callcredit Limited (trading as TransUnion). With effect from 30 April 2019, Callcredit Limited’s legal name will be TransUnion International UK Limited.
TransUnion is a controller of the personal data that you provide us with on the website or if you contact us using the details below. This means that it is responsible for ensuring that the personal data is used fairly and lawfully.
This privacy notice explains TransUnion’s use of the personal data that you provide us with on the website and if you contact us using the details below. TransUnion is also the controller of the credit data (and the other information relevant to your financial standing) that you can access through the website. Please refer to https://www.transunion.co.uk/crain to find out more information about how TransUnion collects and uses credit data in its capacity as a credit reference agency.
You can contact us by sending an email to email@example.com.
WHAT WE USE PERSONAL DATA FOR
This section explains the purposes for which we use personal data about you. More detail about the types of personal data that we might use for these purposes can be found in section 3 below.
Verifying your identity
The information you provide on signing up to the website will help us to verify your identity so that we know we are providing your credit history to the correct person. We do this by checking the information you give us against databases such as the electoral roll and your credit file.
Please refer to our Bureau Privacy Notice for more information about how we use personal data in connection with this service.
Providing our website and our products and services to you
We use personal data to provide you with products and services through our website. This includes products and services such as:
- your credit report and credit score.
- premium Noddle services such as Noddle Web Watch, Noddle Alerts and Noddle Improve.
We also use your personal data to contact you about our services. For example, we may contact you by email or SMS message to let you know when your new credit report is ready.
Prevention and detection of fraud and other crime
In order to detect or prevent fraud (for example, to ensure that no-one has fraudulently accessed your account or to confirm you have only entered information about yourself), we may use personal data from other sources to corroborate your details. We may use third parties to undertake these checks on our behalf.
The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found by visiting the Cifas website.
We use personal data for marketing purposes. This includes showing you advertisements or otherwise informing you about products and services that we think may be of interest to you. These may relate to products and services offered by any current or future member of TU UK (see section 5) or any third party.
We will not sell your personal data to third parties for marketing purposes but we may use it to promote third parties’ products and services.
How we get to know you
We continuously strive to improve, develop and expand our range of services and to provide our customers with a more personalised experience. So that we can do this and present relevant services and partnering arrangements to you, we need to understand your possible needs, interests, and preferences. To do this we build up insight about you throughout your relationship with us in the following ways:
- from your application for any services on the website, the particular services you chose, and how you use them (for example, we may look at your credit report for any features that may suggest a life event or a change in your financial circumstances);
- from how you engage with any of the third parties involved when you use your selected services on the website.
These activities might be when you use the website, and in your dealings with us generally.
What we contact you about and how
Whether or not and how you hear from us with marketing information is always in your control. We will only contact you according to your choices about:
- whether you want to receive information about our products and services, and/or the products and services of third parties, and
- what methods of communication you have selected.
You can make these choices when you first register with us, and you can also make these choices in the preference centre, located within the My Account section of the website. If you click ‘unsubscribe’ within our marketing mailings and SMS messages you will be directed to the preference centre where you can make your changes.
Your marketing preferences will not affect how we contact you for non-marketing purposes. You will still hear from us by a range of contact methods as part of our relationship management (see below) or if contacting you is an integral part of the service you have signed up to. An example of this is your monthly reminder email letting you know that your new credit report is ready.
If you agree that we can send you information about third parties, this may be from the third parties we work with to bring you the particular service you sign up to, or those whose goods and services may be relevant to you. For example, if during sign-up you said you were registering with us because you were trying to get a mortgage, we may present you with mortgage deals.
We do not sell your personal details to third parties for marketing purposes. If you select to receive information from us about relevant third party goods and services, this doesn’t mean that you will hear from them directly or that we will give them your personal details, unless you follow up directly with them. (In this case we will exchange a minimal level of information, such as your email address and name, as we may receive a small commission from the third party if you take up their goods and services.)
We may also show you advertisements on the website or via online advertising platforms. Section 11 below tells you about cookies and how you can manage your cookie preferences.
We use personal data for relationship management purposes. Relationship management is the ongoing maintenance of our relationship with you. This could include activities such as letting you know about product changes or planned maintenance activity, providing you with technical support or dealing with your enquiries.
When we contact you for relationship management purposes it might be through any of the means available to us, such as by email, SMS, telephone or on the website.
Administering, monitoring and improving our websites
We use information such as how different people navigate around our websites, how long they spend on particular pages and whether they download any of our content in order to help customise and improve the user experience of our websites. This can include recording the clicks and mouse movements of our users, but any personal information is screened out of these recordings to help protect your privacy.
These activities allow us to tailor the website to match your interests and preferences better and to present you with more relevant content and offers. And they help us understand who has visited which pages to determine the most popular areas of the website.
This information is also used for security and system administration and to generate aggregate non-personalised information for use by us, our business contacts, selected third parties, sponsors or advertisers (such as anonymous statistics related to the take up or use of services, or to patterns of browsing).
Product or systems development and testing
We may sometimes use personal data while improving, developing or testing our products and systems. This includes making sure that our security measures are working properly. Where possible, we will anonymise or pseudonymise the data before doing this.
Legal and regulatory purposes
We may use your personal data for legal and regulatory purposes. For example, this might include responding to complaints or enquiries from you or a regulator about how we have used your personal data.
The information you give us may be combined with other information about you that is obtained from other sources, and the combined data may be used in accordance with this Privacy Notice. For example:
- The information you give us may be compared with data available elsewhere to verify your identity or validate the information you have provided (for example in the context of anti-fraud measures).
- Anonymised information about you may be combined with information about your devices (or cookies placed on your devices) to improve the quality and relevance of advertising material on websites you visit.
- We may combine information about how you use the website with the other information we hold about you in order to help us develop a better and more detailed understanding of the way different types of individuals use the website and what their preferences and interests are.
WHAT KINDS OF PERSONAL DATA WE USE, AND WHERE WE GET IT FROM
We obtain and use information from various different sources. These are summarised in the following table.
Type of information Description Source Name and contact details This is basic personal data about you, and how to get in touch with you. This information is usually provided directly by you, typically through our website. Some of it is also matched with data on your credit file. Other identifying information This is other information that we need to help identify who you are, such as your date of birth and address history. In some cases, such as where you have changed your name, we may require physical documents such as a deed poll or marriage certificate. Information you ask us to monitor If you use the Noddle Web Watch service, you can provide us with information such as credit and debit card numbers, email addresses and telephone numbers for us to monitor. Your credit file This is information about your credit history, such your loans, mortgages and other credit arrangements, your repayments, and your financial associates. It also includes information such as court judgments, bankruptcies and IVAs that may have been made against you, as well as your current and previous names and addresses. We also keep a record of who has previously made searches of your credit file, and any disputes and queries that have been raised by you. Your credit file also contains fraud prevention indicators.
More details about this information can be found at www.transunion.co.uk/crain
We gather this information, in our role as a credit reference agency, from a range of different sources, including lenders. Information court judgments and insolvency-related events comes (indirectly) from the courts. Address information is obtained from the electoral register, which is supplied to us by local authorities. Fraud prevention indicators are provided by Cifas. Transaction history This is information about what products and services you have subscribed to or bought on the website, when you bought them and, if applicable, how much you paid for them. We produce these records ourselves. Contact history This is information about our contact with you. It also includes your behaviour in response to our interactions with you, such as whether you have opened our emails or clicked on a link. Device information This is information about the device you are using to access our websites, such as the type of device, its operating system, browser, IP address, screen resolution and what cookies are on it. We produce these records ourselves by monitoring your use of our websites. Website usage This is information about your use of our website, such as what pages you have visited and what content you have downloaded. It includes information about how you arrived on our website, navigated around it and browsed away from it (including dates and times), the services you viewed or searched for, page response times, download errors, length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse-overs). Cookies and similar technologies may be used to help us do this – see section 11 below. Third party data This information that we obtain about from third parties and associate with you or your devices. We may obtain this data from various different data suppliers.
You are free to choose whether or not you give us your personal data. However, if you are signing up to one of our products or services we might not be able to provide you with that product or service if you do not give us the information we need in order to do so.
WHAT OUR LEGAL GROUNDS FOR HANDLING PERSONAL DATA ARE
This section explains the basis on which we process your personal data in connection with the website. Our basis for acting as a credit reference agency is explained separately at https://www.transunion.co.uk/crain.
Performance of our contract with you
When you sign up to services on the website, we agree to provide you with certain services as set out in the Terms and Conditions. We need to use some of your personal data in order to be able to provide you with those services. For example, we need to know what services you have signed up for, and we need to process your credit or debit card details in order to take payment from you for any premium services you buy.
We rely on your consent for sending you marketing materials by email, telephone or SMS. You can give or withhold consent when you first sign up to the website, and you can subsequently withdraw your consent through your account settings or (in the case of email) by clicking the “unsubscribe” link. See the information about “Marketing” in section 2 above for more details.
The UK’s data protection law allows the use of your personal data where necessary for legitimate purposes provided that this isn’t outweighed by the impact it has on you. The law calls this the “legitimate interests” condition for processing personal data.
The legitimate interests we are pursuing include:
Interest Explanation Promoting knowledge among consumers about their credit history and its implications for them. Allowing consumers to challenge incorrect data on their credit report. It is important that consumers are well-informed about their credit history and how it may be taken into account by lenders. Where a consumer has been declined credit we help them understand why this might be and this allows them to challenge information on their credit report if it is inaccurate. Monitoring and securing our systems and data Some of the ways we use personal data are justified by the need to ensure that our systems and the data we make available through the website are kept secure and only made available to the correct people. Commercial interests Like any commercial organisation, we seek to earn revenue through the services that we provide to our customers and clients.
WHO WE SHARE THE PERSONAL DATA WITH
Our group companies
We may share your personal data among the members of TU UK. If we do so, then use of the data by those companies will be governed by this Privacy Notice. A list of relevant TU UK companies is set out below, although the list may be updated from time to time.
Group company Role Main trading address Registered office Callcredit Information Group Limited
(company no. 4968328)With effect from 30 April 2019, this company’s legal name will be TransUnion Information Group Limited.
Our holding company One Park Lane, Leeds, West Yorkshire LS3 1EP Callcredit Limited
(company no. 3961870)
Supplier of your credit history and the operator of the website Recipero Limited
(company no. 3794898)
Provider of other TU UK consumer services Recipero, Inc
(company no. 5542430)
720 S. Colorado Boulevard, Penthouse North, Denver, Colorado 80246, USA Callcredit Operations UAB
(company no. 302689020)
Provider of some back-office support functions. Zalgirio Arena, Karaliaus, Mindaugo pr. 50, Kaunas LT- 44333, Lithuania Vilniaus m. sav . Vilniaus m. J. Jasinskio g. 16B, LT-01112, Lithuania
We may provide your information to third parties who help us use it for the purposes described in section 2. For example:
- Our database of personal data may be hosted or otherwise processed by third parties on our behalf.
- We use a third party email broadcasting service in order to send you service emails or SMS messages or (if you have agreed to receive them) marketing emails.
- We use payment service providers if you buy any premium Noddle products.
- We use a third party to help us perform the dark web monitoring services if you use Noddle Web Watch.
- We might use market research companies to help us better understand our customers.
These service providers will not be allowed to use your information for their own purposes or on behalf of other organisations, unless you agree otherwise.
Online advertising platforms
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.
Sometimes we may provide information associated with you to third parties who operate other websites (such as social media platforms) so that we can show you relevant advertisements while you are using those websites. This information will be protected so that you can only be identified if the third party already knows you – the information we provide only tells them that you are a Halifax Credit Checker user.
If we sell our business to a third party, or go through a corporate reorganisation, we will transfer personal data to the company that acquires the business.
We may sometimes need to pass personal data to a regulator such as the Information Commissioner’s Office.
Sharing of anonymised data with third parties
We may share anonymised information with other third parties, but only where the information cannot realistically be identified as relating to you.
WHERE THE PERSONAL DATA IS STORED AND SENT
We are based in the United Kingdom and will access and use your information from here. However, we also have operations elsewhere in the European Union – currently the Netherlands, Lithuania and Spain – and personal data may be accessed from there too. In these cases, the use of the information in those locations is protected by European data protection standards.
We also send information elsewhere in the world. For example:
- Sometimes another group company or branch office based overseas may need to use the data in accordance with this Privacy Notice.
- We may use cloud-based technology or a data centre or backup facility overseas, and people in other countries may also need to access data for purposes such as technical support or system development and testing.
While countries within the European Union all ensure a high standard of data protection law, some parts of the world may not provide the same level of legal protection in relation to personal data. As a result, when we do send personal data overseas, we will make sure that suitable safeguards are in place to protect the information. For example, these safeguards might include:
- Putting in place a contract with the recipient containing terms which have been approved by the authorities as providing a suitable level of protection.
- Sending the information to an organisation which is a member of a scheme which has been approved by the authorities as providing a suitable level of protection. One example is the “Privacy Shield” scheme that has been agreed between the European and US authorities.
HOW LONG THE PERSONAL DATA IS KEPT FOR
We will keep your personal data for as long as you are a member of the website and for a period of one year from when your account is closed. We keep the data for that extra period of time in case we need to respond to any enquiries from you (for example, if you have any questions about the amount we have billed you for any premium Noddle services) or from any regulators. We may keep anonymised data for a longer period of time for analysis purposes.
We may close your account if you do not use it for a long time, and you can close your account at any time by contacting us at firstname.lastname@example.org. Please see the Terms and Conditions for more information about this.
WHETHER THE PERSONAL DATA IS USED TO MAKE AUTOMATED DECISIONS ABOUT YOU OR TO PROFILE YOU
We perform the following automated decision-making and profiling activities using your personal data. When we refer to profiling, we mean using personal data to make predictions about you, or to categorise you into particular groups.
As explained in section 2 above, we will use the information you provide on registration to help us to verify your identity so that we know we are providing your credit history to the correct person. We do this by checking the information you give us against databases such as the electoral roll and your credit file. This is an automated process, and it can result in you being declined access to the services available on the website if we can’t verify your identity.
Thin file upgrade process
If you sign up to this website but do not have enough credit history to enable us to provide you with a credit report, we will continue to periodically check your credit file and, if you do develop enough of a credit history, we will automatically upgrade your account.
Credit scores and ratings
We create your credit score and rating based on information contained in your credit report. Please refer to www.transunion.co.uk/crain to find out more.
Account management, marketing and website personalisation
If you do not use your account for a long time we may automatically categorise you as a dormant user. While you are classed as a dormant user we may attempt to reengage with you, for example by sending you messages reminding you about your account and warning you that if you do not use the account it may be closed.
We may also categorise you alongside other data subjects based on information such as how you move around the website or what products and services you seem most interested in so that we can tailor advertisements for particular groups of people at the same time or in order to personalise the website for particular groups of people.
As explained in section 2 above, we build up a relationship profile from your dealings with the website and may use this to contact you with marketing information in accordance with your contact preferences.
YOUR RIGHTS IN RESPECT OF THE PERSONAL DATA THAT WE HOLD ABOUT YOU
You have several different rights in relation to the personal data that we hold about you. These are briefly described below. To enquire about exercising these rights, please use the contact details set out in section 1.
- Access: You have a right to find out what personal data we hold about you, and certain other information such as how we are using it. You can see some of this information by visiting the “My Account” section of the website.
- Withdrawal of consent: When we rely on your consent to use your data (see section 4 above), you have the right to withdraw that consent at any time. You can do this by contacting us, or through your account settings or (in the case of marketing emails) by clicking the “unsubscribe” link.
- Objection to direct marketing: You have the right to object to us using your personal data for direct marketing purposes. If you do this we will stop using it for those purposes.
- Rectification: If the information that we hold about you is inaccurate or out of date, you have a right to ask us to correct it.
- Objection to legitimate interests: If you disagree with us relying on the legitimate interests grounds for using your personal data (see section 4 above), you can object to us doing so. We will then reassess the extent to which we can continue to use the data in light of your particular circumstances.
- Erasure: In certain circumstances you can ask us to delete your personal data from our systems. However, this usually won’t apply to all of your data because we might have good reason for needing to keep some of it.
- Restriction: In some circumstances you can ask us to restrict the ways in which we use your personal data.
- Portability: You have the right to receive some limited kinds of information in a portable format. Please note that this does not apply to the information on your credit report.
Some special rules apply when you make a request about information on your credit report; please refer to www.transunion.co.uk/crain to find out more.
WHO YOU CAN COMPLAIN TO IF YOU ARE UNHAPPY ABOUT THE USE OF YOUR PERSONAL DATA
We try to ensure that we deliver the best levels of customer service but if you are not happy you should make contact so that we can investigate your concerns. Please contact us by sending an email to email@example.com.
You can also contact our Data Protection Officer at firstname.lastname@example.org.
You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), which is the body that regulates the handling of personal data in the United Kingdom. You can do this online through the ICO’s website at www.ico.org.uk, by telephone on 0303 123 1113, or by writing to them at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF.
WHAT COOKIES ARE USED ON THE WEBSITE
A cookie is a small file of letters and numbers that we put on your device. We use the following kinds of cookie:
- Strictly necessary cookies. These are cookies that are required for the operation of the website. They include, for example, cookies that enable you to log into secure areas of the website.
- Analytical/performance cookies. These cookies allow us to recognise and count the number of visitors and to see how visitors move around the website 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. They also allow us to tell if you have reached our website from one of our advertising partners so that we can meet our contractual commitments to that partner.
- Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences.
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below.
Name Purpose More Information _utma
These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they have visited. https://www.google.com
source This cookie is used for the user session to work correctly.
This cookie holds additional information passed to us from a third party for use on the site, for example to pre-fill the sign-up form. guest_id, original_referer This is a Twitter widget. Widgets let you display Twitter updates on your website or social network page. http://twitter.com/about
__stid These cookies are used to provide the service that allows you to share certain articles on the site with friends/colleagues via various social networks. https://sharethis.com/privacy __uset (Sharethis) These cookies are used to provide the service that allows you to share certain articles on the site with friends/colleagues via various social networks. https://sharethis.com/privacy C1
__ResultModelTempData + number (for example __ResultModelTempData1)
This is created as part of the signup process. _gcl_aw and _gcl_dc These cookies track the success of our Google ad campaigns and enable us to make sure we do not continue to target these campaigns at existing customers. https://support.google.com/tagmanager/answer/7549390?hl=en
You can block cookies using your browser settings that allow you to refuse all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access parts of our website or use some of its features. For more information about this, and about cookies in general, you may wish to visit www.aboutcookies.org.