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Privacy Policy | CommuterClub

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Privacy Note

CommuterClub Ltd is committed to protecting and respecting your privacy. This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting you ("our site") are accepting and consenting to the practices described in this policy.

For the purpose of the Data Protection Act 1998 (the Act), the data controller is Petko Plachkov, CommuterClub Ltd of Rivington Place, London, EC2A 3BA.

Information we collect

The information we collect is generally used to communicate with you and improve our services where possible, and specifically, to process your credit application, process payments or enable third parties to carry out technical or commercial supporting functions.

We also collect your personal data, such as your name, e-mail address, billing address, telephone number, bank account number, financial information (about your income and expenditure) and ticket order details so we can assess your application for credit. We also analyse data about participants in order to provide a safe user environment for all users. Examples of the data we may collect and analyse include the Internet protocol (IP) address used to connect your computer to the Internet, login, password, computer and connection information such as browser type and version, your operating system and platform, the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), cookie number, products you viewed or searched for, your purchase history, personal preferences and any phone number recorded or used to call our customer services number.

We will not sell, distribute or disclose information about you or your personal usage of our site without your express consent or unless required or permitted to do so by law.

How we may use your information

In assessing your application for credit, we will share your personal data with credit reference and fraud prevention agencies and Retail Money Market Limited (RateSetter), who assist us in underwriting your loan. We may also outsource certain services in connection with the administration of credit to RateSetter. We may record communications with you (whether electronic or by telephone) to offer you additional security, to ensure we comply with our legal and regulatory obligations and to ensure we maintain the best possible service and quality standards in managing your account(s).

In managing any credit agreements you have with us, we may provide details to credit reference agencies with regular information about you and any financial associate if you have one. We may also provide details to credit reference agencies with regular information about your agreement with us, including payment history, changes in personal information and general about the behaviour of your account. Other lenders may use this to make decisions on future applications for credit or for the purpose of tracing debtors. We may also obtain information from credit reference agencies and public sources, including electoral roll, to verify your identity or determine your financial status.

If false or inaccurate information is provided and any possible fraud is identified, details may be passed by us or RateSetter to fraud prevention agencies to prevent fraud and money laundering. You can ask the credit reference agencies for a copy of your credit file - they may charge you for this service. If there is anything incorrect of your credit file, you can ask them to add a Notice of Correction to your credit file. The main credit reference agencies in the United Kingdom are:

  • Experian Limited
  • Equifax Limited
  • Callcredit Limited

You can find more information about how we process your information in connection with your application for credit in the draft credit agreement. We may also monitor customer traffic patterns, usage of our site and related information in order to optimise your use of our site and we may give aggregated statistics to a reputable third-party, but these statistics will include no information personally identifying you.

We may combine your information with information lawfully obtained from other third party sources and use it to optimise your use of the Site and improve our services to you.

We may also use the information we gather to notify you about important functionality changes and alterations to our site, or offers of products, services or information that might be of particular interest to you.

We may share the information we gather with trusted business and technical partners for operational purposes such as handling orders, delivering products and services, processing credit and debit card payments, sending communications, providing customer service functions, for fraud detection services and for data analysis. Those of our partners who need to access personal information to perform their business services, may not use the data for other purposes. In order to fulfil your ticket order we will share your route and ticket information with our ticketing suppliers. We may also share your information with the relevant Train Operating Company if you opt-in to relevant marketing information. We will never share information for marketing purposes without your express consent.

Where you have consented for us to do so, we may collect information on your behaviour and the use of your travel card so we can regularly provide you with updates on your regular journeys, such as delays, planned works and disruptions. We may also provide you with offers and/or discounts available to you with selected retailers on your journey, however, as we take your personal information very seriously it is generally not our policy to share your personal information with such third parties.

We may also share data with law enforcement agencies and/or third parties in respect of information requests for criminal investigations and alleged illegal activities. The personal information we disclose may include your name, billing/delivery address, telephone number, email address, and order history.

Where any fraudulent activity is detected on our site, or, without limitation, in connection with the breach of intellectual property rights through the use of our site, we may release personal information in order to comply with any applicable regulation or assert our rights as well as our business partners.

Your information may also be transferred to another company in the event of sale of our company to a third party.

This Privacy Policy applies to the use of our site generally. If there is any dispute between the terms of this policy and the terms of any credit agreement you enter into with us, the terms of the credit agreement will prevail.

Where we store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; 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.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at Our site 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.

Access to information

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of ?10 to meet our costs in providing you with details of the information we hold about you.

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

Please check back frequently to see any updates or changes to our privacy policy.

Information about our use of cookies

Our site uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our site, use a shopping cart or make use of e-billing services.

Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies. These are used to recognise you when you return to our site. 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).

Targeting cookies. These cookies record your visit to our site, the pages you have visited and the links you have followed. We will use this information to make our site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose, however where we do so we generally obtain your consent.

Internet cookies are common and won't cause any harm to your device. No personally identifiable information is stored within cookies; therefore we recommend you leave these switched on. You can configure your Internet browser to accept or reject certain cookies or inform you when a cookie is saved.

We do not cross the information recorded in the cookies with the personal information collected at the time of your registration on the Site or with your online activity.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of 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 all or parts of our site.


Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to

CommuterClub Ltd. Rivington Place, London, EC2A 3BA, Authorised and regulated by the Financial Conduct Authority
License Number 723733. Registration details Registered in England and Wales