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Welcome to Commuter Club's privacy notice.
Commuter Club respects your privacy and is committed to protecting your personal data and will only share it with others for the purposes set out in this Privacy Notice. This notice gives you information on how and why we collect, hold, process, share and how we look after your personal data. This notice also tells you about your rights and how the law protects you.
Throughout this notice, "you" means the customer. We regularly review our Privacy Notice to make sure that we continue to respect your privacy and as a result may make updates. When we do so, we will provide you notice of the most up to date information on our privacy practices.
Commuter Club Ltd is the controller and responsible for your personal data (collectively referred to as Commuter Club, we, us or our in this privacy notice. If you have any questions about this notice or how we handle your personal information, please contact us on [email protected]. Commuter Club are registered with the Information Commissioner's Office and you have the right to complain to them should you find that we have not satisfactorily processed your personal data in line with this notice, our regulatory obligations or your legal rights.
Any questions you may have in connection with this notice or if you simply wish to update your preferences or exercise your legal rights you have, you can do so by writing to [email protected] and marking it Data Privacy Preferences. We will ensure our responsible person for data protection will take care of your query as quickly as possible.
This privacy notice aims to give you information on how Commuter Club collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to use our services or to receive our newsletter or you provide your permission for us to market to you about our services or goods/services provided by third parties we work with - this may include rewards we may offer through the use of our Services.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
This privacy notice supplements the other notices and is not intended to override them.
This 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.
We will collect your permission in order to process your information for marketing purposes, this includes contacting you about our products and services, borrowing more money and our offers.
Where you discuss sensitive data with us, for example any medical information which may impact your ability to repay your loan or borrow more money, we will capture explicit permission from you in order to store and process this information about you.
Where you have applied for a loan, we will use our legitimate interests to pass this to third parties who provide funding facilities or services to you or us and we will process your information for such purposes, this includes existing loans, any potential new loans you process with us for the purposes of renewing your travel card in which we will perform certain checks, including credit searches (as outlined in section 7 of this notice).
We will also process your information as per our contractual and legal obligations to ensure we and our selected partners are lending safely, responsibly and legally. This includes:
Personal data, or personal information, means any information about a living individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you when you visit our website(s) or when you register an interest or which are necessary to obtain in order to provide the services to you.
We have set out in the table below the categories of data subject and types of personal data we may collect, use, store and transfer.
The below information sets out more information about the types of personal data we may collect, use, store and transfer.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Where we need to collect personal data to satisfy our legitimate interests, or in order to provide the services to you under the terms of any of the agreements you enter, we may not be able to offer or perform our services to you. In this case, we may have to cancel, suspend or terminate part or all of the services offered to you but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Profile and Contact Data and Financial and Transaction Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
Automated technologies or interactions. As you interact with our website, we may automatically collect Usage and Experience Data and Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, third party and other similar technologies, for example website(s) analytics providers. We may also receive Usage and Experience Data and Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources, for example using (i) credit reference agencies, government databases, data analytics and other screening providers to be able to identify you, obtain credit information (including affordability information) or monitor transactions and to comply with our legal obligations or perform the services to you; (ii) third party dispute resolution providers we use or are legally required to deal with; or (iii) other third party funding partners who provide us or you with financing products.
We may process your personal data for a variety of reasons that are justified and are allowed under data protection laws, which forms the legal basis on how we process your personal data. Most commonly, we, our funding partners and selected third parties, that provide you and us the services and products we offer, will use your personal data in the following circumstances:
We strive to provide you with choices regarding personal data uses, particularly around marketing and advertising. With your permission, we may:
You have the right to withdraw consent to marketing at any time by and free of charge. We will allow you to do this by updating your preference through our website(s) or mobile application or you can contact [email protected].
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website(s) and Services may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy in our legal section of our website.
We may have to share your personal data or other information about you with others in a variety of ways as described in this section. We may share your personal data or other information for the following reasons:
With your permission: we will also share your personal data and other information if you authorise an account connection with a third-party account or platform. We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
When you apply for a loan, or likely to take out a new loan with us or through one of our funding partners, we will look at your credit file at credit-reference agencies ("CRAs") such as Call Credit, Equifax or Experian. The CRAs will give us credit information about you including information from the electoral register. If you're a borrower or prospective borrower, this credit search is used to check your identity, your eligibility for a loan including making credit decisions about you. The CRAs will add details of our or our funding partners' searches and your application to the record which they hold about you. When you become a borrower, the CRAs will also add details of your loan agreement with us or our funding partners including the payments you make under it and any default or failure to keep to its terms. Your credit-reference agency records will be seen by other organisations that make searches with those agencies. Information held about you by the CRAs may already be linked to records relating to one or more of your partners. For the purposes of this application you may be treated as financially linked and your application will be assessed with reference to any "associated" records.
While you are a customer of ours and/or one or more of our funding partners, we may carry out extra or ongoing credit searches so we can manage your account and process any potential renewal terms. We and other organisations may use and search these records (including access and use from other countries) for example to:
The identities of the CRAs, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs can be obtained by requesting this from us at [email protected] This information is also accessible from each of the three main CRAs - clicking on any of these three links will also take you to the same document:
Call CreditWe share your personal data within the Commuter Club Group. This may involve transferring your data inside the European Economic Area (EEA). We will not pass your data outside of the EEA so there won't be any international transfers of data.
Whenever we work with other third parties who provide a service for you in order for us to operate our legitimate interest, for example our cloud hosting solutions, there may be transfer your personal data inside of the EEA. Where we do so, we will ensure that we only work with such companies that will have a strong degree of protection in relation to your data and that all the appropriate safeguards are in place.
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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties 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.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax, financial regulatory and other legal purposes.
In some circumstances you can ask us to delete your data: see Request Erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out below, please contact us at [email protected].
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you 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 or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to 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. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, 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 override 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.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We may revise this Privacy Notice from time to time to reflect changes to our business, the website(s) or Services, or applicable laws. The revised Privacy Notice will be effective as of the published effective date.
If the revised version includes a substantial change, we will provide you with 30 days prior notice by posting notice of the change on our website. We also may notify Commuter Club Users of the change using email or other means.
Device Information means data that can be automatically collected from any device used to access the website(s) or Services. Such information may include, but is not limited to, your device type; your device's network connections; your device's name; your device IP address; information about you're your device's web browser and internet connection you use to access the website(s) or Services; Geolocation Information; information about apps downloaded to your device; and biometric data (e.g., Touch ID/Fingerprint to verify your identity or to authenticate a transaction).
Geolocation Information means information that identifies, with reasonable specificity, your location by using, for instance, longitude and latitude coordinates obtained through GPS or WiFi, your IP address or cell site triangulation.
Information Commissioner's Office means the UK regulator for the protection of personal data and electronic communications also known as the ICO. You can contact the ICO in writing at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF United Kingdom, or by visiting their website at ww.ico.org.uk.
Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Personal data means information that can be associated with an identified or directly or indirectly identifiable natural person. "Personal Data" can include, but is not limited to, name, postal address (including billing and shipping addresses), telephone number, email address, payment card number, other financial account information, account number, date of birth, and government-issued credentials (e.g., driver's license number, national ID, passport number).
Process means any method or way that we handle Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, and consultation, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of personal data.
Services means any products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by Commuter Club under the Customer Agreement.
CommuterClub Users means an individual who uses, applies for, enters into the services or products we offer, accesses the website(s) and has established a relationship with Commuter Club (for example by entering into a loan, or purchase a travel ticket).
Website(s) means the websites, mobile apps, official social media platforms, or other online properties through which Commuter Club offers the services and which has posted or linked to this Privacy Notice.
Usage Data means information we collect from your phone, computer or other device that you use to access the website(s) or Services. Usage Data tells us how you use the website(s) and Services, such as what you have searched for and viewed on the site(s) and the way you use our Services, including your IP address, statistics regarding how pages are loaded or viewed, the websites you visited before coming to the website(s) and other usage and browsing information collected through Cookies.
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to [email protected].
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