Introduction

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.

Important Information about this Privacy Notice

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.

Who do I contact about this Privacy Notice

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.

1. Important information and who we are

Purpose of this privacy notice

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.

Third-party links

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.

2. Our lawful basis to process your information

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:

• Performing adequate checks to confirm your identity and to ensure your suitability and affordability for a loan;
• Protecting and preventing criminal activity, for example any fraud or money laundering
• Managing the loan and recovering any monies you owe to us or our funding partners (including where necessary through court proceedings)
• Reporting loan and repayment information with credit reference agencies
• Responding to and complying with our regulatory requirements including any information we have to share to the Financial Conduct Authority, the Financial Ombudsman Service, or any other person which we are regulated by or provides oversight over us).

3. The data we collect about you

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.

More information about the types of personal data

The below information sets out more information about the types of personal data we may collect, use, store and transfer.

• Identity, Profile and Contact Data includes first name, middle name, last name, username or similar identifier, password, pin code, title, date of birth, gender, profile pictures or avatars, government ID documents, biometric data, residential address, electoral roll and residency information, delivery address, billing address, email address and telephone numbers, social media information about you and your contacts (if you decide connect your social media profile with us), your interests, preferences, feedback and survey responses. We may collect additional information from or about you from third party sources such as companies in which we work with to provide you with rewards, data providers, financial institutions (including credit and credit information services) where permitted by law;
• Financial and Transaction Data includes bank account, funding instruments, payment card details, information in performing the Services, Identity, Profile and Contact Data, financial account information about you, information held with credit reference agencies for the purposes of determining affordability and creditworthiness, information about and from other financial products you have, details about payments to Commuter Club or our funding partners, other details of products and services which are linked to payment transactions, funding instruments used to complete transactions.
• Usage and Experience Data includes (i) Device Information, Usage Data and Geolocation Information, (ii) details about your interaction with our website(s) and employees including communications, payments, reviews, research, customer services communications (including calls, emails, texts, emails and letters) which will record and/or monitor to provide our services, training, continual improvement and meeting our regulatory obligations and (iii) your experience and behaviour information in interacting with us and our website(s) primarily to improve your experience when using our services. If you request or participate in optional site features, research or request enhanced services or other elective functionality, we may collect additional information from you.;
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

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.

If you fail to provide personal data

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.

3. How your personal data is collected

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:

• Use our services, including applying for, entering into and managing your loan;
• Make any enquiries about us, our services and products;
• Create an account on our website;
• Subscribe to our services, communications or publications;
• Request marketing to be sent to you;
• Enter a competition, promotion or survey;
• Interact with our Customer Services or any other member of our team; or
• Give us some feedback.

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.

5. How your personal data is used

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:

• To make, or assist in making, credit decisions about you, assess lending risks, and to check the details that you have let us and others have;
• To operate and manage your account and any application, agreement or correspondence you may have with us;
• To identify, prevent, detect or tackle fraud, money laundering and other crimes;
• To contact you via email, texts, letters, phone or send you push notifications about managing your loan with us, or our funding partners, including if you fall into arrears or if we have out of date information;
• To contact you about our products and services, unless you tell us that you prefer not to receive marketing;
• To collect and manage payments, and to recover any debt you owe us both on your current loan and on any previous, prospective or subsequent loans, unless you advise us otherwise;
• To manage interest on your account;
• To respond to complaints;
• To exercise our rights set out in agreement or contracts and to comply with our regulatory obligations;
• To detect, investigate, report, monitor and analyse our business;
• To carry out market research, to develop and manage our brand, product and services;
• To carry out internal and external audits;
• To test our processes and systems;
• To process, issue, cancel, manage, terminate and/or redeem travel tickets you obtain through us
• To obey laws and regulations that apply to us and our funding partners;
• To manage security and risk for us, our funding partners and you.

Marketing

We strive to provide you with choices regarding personal data uses, particularly around marketing and advertising. With your permission, we may:

• Market to you by delivering marketing materials about Commuter Club products and services and any products and services of unaffiliated third party businesses. We may though process personal data to tailor the Services or website experiences to better match our understanding of how you use our Services or match your interests;
• Provide personalised services offered by Commuter Club on third-party website and online services. We may use your personal data and other information collected in accordance with this notice to provide targeted display, feature or offer to you on our or third-party websites. We may use cookies and other tracking technologies to provide these online services and/or work with other third parties such as advertising or analytics companies to provide these services;
• Provide you with location-specific offers, services, promotions, search results advertising and other personalised content. We may also use location-specific or geolocation functionality through the Services to enhance the security of our website(s) and the Services, including ensuring we are offering the Services in the correct location.

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].

Cookies

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.

6. Disclosures of your personal data

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:

• Other members of the Commuter Club corporate family. We may share your personal data with members of the Commuter Club family of entities to, among other things, provide the Services you have requested or authorised; to manage risk; to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements and to help us manage the availability and connectivity of Commuter Club products, website(s), services, and communications;
• With other companies that provide services to us. We share personal data with third-party service providers that perform services and functions at our direction and on our behalf to be able to make available our website(s) and product and services. These third-party service providers may also provide you with our products and services, verify your identity, assist in processing transactions, send you advertisements for our products and services, provide customer support; and to monitor your interactions with our website(s);
• With other financial and commercial institutions we have partnered with. We share personal data with other financial institutions that we have partnered with to either jointly create and offer products or service, or to be able to offer our services. These financial institutions may also use this information to market and offer Commuter Club-related products, unless you have given consent for other uses or you already have a relationship with such financial or commercial institution;
• With other parties to manage our business or help us facilitate with our products and services. We may share information with travel operators to be able to issue and manage your travel card, credit reference agencies, fraud prevention agencies, companies you ask us to share data with, other parties where we are legally obliged to, for example the Financial Ombudsman Service to handle any dispute or complaint you raise, or the police in relation to criminal activity, internal or external auditors, any company we use to process your information to manage our business and our regulators
• With other third parties for our business purposes or as permitted or required by law. We may share information about you with other parties for Commuter Club's business purposes or as permitted or required by law, including:
• If we need to do so to comply with a law, legal process or regulations;
• To law enforcement authorities or other government officials, or other third parties pursuant to a subpoena, a court order or other legal process or requirement applicable to Commuter Club or Commuter Club's corporate family;
• If we believe, in our sole discretion, that the disclosure of personal data is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
• To protect the vital interests of a person;
• With credit agencies and data processors for credit reference checks and anti-fraud and compliance purposes;
• Travel operators to be able to issue and manage your travel card
• To protect our property, services, products and legal rights;
• To facilitate a purchase or sale of all or part of Commuter Club's business;
• To help assess and manage risk and prevent fraud against us, Commuter Club customers and fraud involving our website(s) or use of our services or products;
• To banking or other financial partners as required;
• To companies that we plan to merge with or be acquired by; and
• To support our audit, compliance, and corporate governance functions.

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.

7. Credit searches

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:

• Help make decisions about credit and credit-related services and other facilities for you and members of your household;
• Verify the accuracy of the data you have provided to us;
• Trace debtors, recover debt, prevent fraud, and to manage your accounts and other facilities;
• Check details on proposals and claims for all types of insurance;
• Check details of job applicants and employees; and
• Check your identity to prevent money laundering unless you give us other satisfactory proof of identity.

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 Credit
Equifax
Experian

8. International transfers

We 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.

9. Data security

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.

10. Data retention

How long will you use my personal data for?

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.

11. Your legal rights

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].

What are my legal rights?

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.

No fee usually required

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.

What we may need from you

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

Time limit to respond

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.

12. Changes to this Privacy Notice

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.

13. Definitions

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.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to [email protected].