Last Updated: 10th July 2015
For the purpose of the UK Data Protection Act 1998 (the “Act”), the data controller is Divido. Divido is registered with the Information Commissioner’s Office for data protection: ZA086930.
1. INFORMATION WE COLLECT
As a credit broker we collect information about you in three different ways.
First, we collect information directly from you, including:
Registration – When you create a user profile on the Website, you may submit personal information including your name, date of birth, telephone number, address, employment information and email address; and Correspondence – We will store any communication between you and us, including by way of phone, online forms, e-mail or otherwise. Second, when you apply for the Divido Services you provide the Merchant (as defined in the End User Terms) with information about yourself which the Merchant then provides to us, including:
Credit Check information – Your name, date of birth, sex, marital status, billing and mailing address, email address, employment information, telephone number, payment instrument information and other financial information; and Identity Check information – Your credit card details, your passport and your driver’s licence. Third, we also receive information about you from other sources, including:
Analytics – We are working with analytics providers and may receive information about you and your web usage from them.
3. USE OF YOUR INFORMATION
Divido shall process your personal data only to the extent, and in such a manner, as is necessary for the following purposes:
- To provide you with the Divido Services
- To conduct, or arrange for a credit agency to conduct, credit checks
- To provide you with information about changes or updates to the Divido Services which affect your rights and obligations
- To provide you with information about the services we feel may interest you, where you consent to receiving such information
- To present content from the Website in an effective manner to you
- To deal with your queries, complaints or concerns
- To provide you with special offers, promotions, surveys and other information about 9. the Divido Platform, where you consent to receiving such information
- For research and development to evaluate and enhance the Divido Platform and For system administration, such as for technical support, computer system processing, security and maintenance and activity verification,
and shall not process your personal data for any other purpose.
4. STORAGE OF YOUR INFORMATION
Your personal data will be stored in Divido’s secure servers and will not be retained for longer than is necessary for the purposes described in clause 3. Once your personal data is not needed, it will be securely deleted to prevent non-authorised third parties from accessing the data during and after the process.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential.
5. PAYMENTS AND THIRD-PARTY PAYMENT PROCESSOR
6. DISCLOSURE OF YOUR INFORMATION
In order to provide the Divido Services to you, we will need to disclose your personal information to the Merchant and the Lender.
We may also disclose your personal information to selected third parties including agents, business partners, suppliers, service providers (such as Stripe for the purpose of processing payments), affiliates, contractors and advisors who may also use your personal data for the purposes described in clause 3.
We may also need to disclose your personal information to:
- Comply with any legal obligation or respond to law enforcement
- Investigate and help prevent security threats, fraud or other malicious activity
- Enforce and protect our rights and properties or apply our Terms of Service and other agreements
- Protect the rights, property or safety of Divido Financial Services Limited, our users, employees or others or
- Prospective or actual purchasers of the Divido Service or a related asset or line of business
7. 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 or the Merchants use to collect your personal data. You can also exercise the right at any time by contacting us at email@example.com.
8. YOUR RIGHTS OF ACCESS TO AND ACCURACY OF YOUR INFORMATION
The Act gives you the right to access and amend personal information held about you. These rights can be exercised in accordance with the Act and by contacting us with your request at firstname.lastname@example.org. Any access request may be subject to a fee to meet our costs in providing you with details of such information.
You can find more detailed information about your rights at the Information Commissioner’s Office website (www.ico.gov.uk).