Effective Date: 19 May 2018
Introduction and Purpose
Prodigy Finance Limited of Palladium House, 1-4 Argyll Street, London, W1F 7LD, United Kingdom (Company No. 5912562) (“Prodigy Finance” or “we” or “us”) is committed to protecting and respecting your privacy. Our United Kingdom Data Protection registration number is Z9851854. Prodigy Finance acts as a lender and administrator of loans. In the United Kingdom it acts as a consumer credit broker and administers loans, funded by alumni, universities, financial institutions and others (the “Lenders”).
Our full details are:
You have the right to make a complaint at any time to the Data Commissioner's Office (ICO), the United Kingdom supervisory authority for data protection issues (https://ico.org.uk/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Table of Contents
Personal Data means any information or data about an individual from which that person can be identified. It does not include data or information where the identity has been removed (anonymous data).
Prodigy Finance may collect and process the following information about you (together “Personal Data”) through your use of the Site or Services:
We may 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. Except in extreme circumstances such as death or a medical illness and only if there is a Legitimate Business Interest (see definition in section 5) for us to do so, we do not collect any special categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, data about your health and genetic and biometric data).
Personal Data may be given to us directly by you or by people or companies authorized by you to act on your behalf (for example, a potential lender, a university, or an alumni association you are a member of). We may also collect Personal Data about you from third parties in connection with our Services (for example, a credit reporting agency). No Personal Data about you will be collected without your consent for us to do so.
Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the Services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Please note that you are not required to provide any Personal Data for publication on the public areas of our Site.
You must notify us by emailing email@example.com within thirty days of any change in your name, physical address, telephone number, email address, or any other information that is necessary for us to provide Services to you.
You must also immediately notify us of your withdrawal or dismissal from your university or school.
We use different methods to collect Personal Data from and about you including through:
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. The transmission of Personal Data via the Internet is not completely secure and, while we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Site; any transmission is at your own risk.
5. How we use your Personal Data
Prodigy Finance acts as a Data Controller when using your Personal Data in providing you with Services and as a Data Processor on behalf of the Lenders.
We use Personal Data held about you in the following ways:
A “Legitimate Business Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service or 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
6. Disclosure of your Personal Data
We may disclose your Personal Data to a parent company, affiliates, franchisees, subsidiaries, joint ventures, or other companies under common control with us, based in the United Kingdom, in any part of the European Economic Area (EEA), or elsewhere. We ensure your Personal Data is protected by requiring all our group companies to follow the same rules when processing your personal data. We transfer Personal Data to South Africa and India for processing. The ICO is aware of this transfer and we have ensured that the recipient parties (including our subsidiary in South Africa) comply with the relevant United Kingdom data privacy laws.
We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions. Some of our external third parties are based outside the EEA so their processing of your Personal Data will involve a transfer of data outside the EEA. Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us at firstname.lastname@example.org if you want further information on the specific mechanisms used by us when transferring your Personal Data outside of the EEA or if you would like details on third parties outside the EEA with whom we share your Personal Data.
7. Data Retention
To ensure fair processing, Personal Data will not be retained by us for longer than necessary in relation to the purposes for which it was originally collected. To determine the appropriate retention period for your Personal Data, we will 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 it was processed and whether the purpose can be achieved through other means as well as the applicable legal requirements.We categorise any identified or identifiable individual person or “Data Subject” into:
In the case of category 1, we will retain all Personal Data for a period of 6 years subsequent to the account having been settled or the completion of the bond investment term. In the case of categories 2 and 3, we will retain all Personal Data for a period of 3 years unless the Data Subject formally requests that their Personal Data be erased. In the case of 4, we collect the visitor’s IP Address for security and audit tracking purposes as well as maintaining digital records of what the visitor did on the website. This data is retained for a period of 90 days.
In some circumstances you can ask us to delete your Personal Data (see Right to Erasure in section 9 below for further information). 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.
8. Fraud prevention and credit agencies
In order to process your application, we may perform credit and identity checks on you with one or more credit reference agencies (“CRAs”). To do this, we will supply your Personal Data to CRAs and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.
We will use this information to:
We will continue to exchange Personal Data about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs. Importantly, we will only be sharing information about your debt with us and your repayment thereof with CRAs in the jurisdiction that, according to our records, you are resident in. If you would like CRAs in other jurisdiction to also receive this information, you need to arrange that yourself.
When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders. The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share Personal Data, data retention periods and your data protection rights with the CRAs are explained in more detail at www.callcredit.co.uk/crain.
Any CRA we use for a search will keep a record of any search, and other lenders may use it to assess applications they receive from you in the future. As a general rule, we will give you at least 28 days’ notice of any decision to file notice on your credit reference file of any default by you in your obligation to make repayments. However, we may not always give you notice beforehand, for example, if an enforcement action is planned.
If you are attending a school in the United States or are a United States resident at the time of making the loan application, then the provisions relating to credit reference and fraud agencies consumer reporting agencies and fraud prevention services shall be set out in the loan agreement that we enter into with you and other legal disclosures that we provide to you.
9. Your rights with respect to your Personal Data
You have the right to:
If you wish to exercise any of the rights set out above, please contact us at email@example.com.
The manner in which we use Personal Data for marketing purposes in the United States is set out in our Privacy Notice (LINK). We will usually inform you (before collecting your Personal Data) if we intend to use your Personal Data for such purposes or if we intend to disclose your Personal Data 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 or by contacting us.
10. Community Lending
Prodigy Finance may communicate with your university to verify your most recent physical address and contact details during the servicing of your loan.
11. Children's Privacy
Our Site is not intended for use by children. We do not knowingly collect Personal Data from children under the age of 13 years. If we become aware that a child under 13 years of age has provided us with Personal Data, we take immediate steps to delete such Personal Data.
12. Do Not Track
The Site is not currently configured to respond to Do Not Track signals sent by Internet browsers.
You agree that we may call you, leave you a message, or send you a text, email, or other electronic message for any purpose related to your expression of interest in our Site, your loan with us, our Services, or surveys or research (each a "Communication"), to the extent permissible by law. You agree that we may call or text you at any telephone number associated with your loan, including cellular telephone numbers and may send an email to any email address associated with your loan. You also agree that we may include your Personal Data in a Communication. In addition, you understand and agree that we may communicate with you in any manner permissible by law that does not require your prior consent.
© Prodigy Finance Limited 2007 - 2019. All Rights Reserved. Prodigy Finance Limited is incorporated in the United Kingdom (Company Number 05912562) with its registered address at Palladium House 1-4 Argyll Street, London, W1F 7LD and registered with the Office of the Information Commissioner (Reg. No. Z9851854). Prodigy Finance is authorised and regulated by the Financial Conduct Authority (firm registration number 709641) for certain consumer credit activities and for investment activities for investors who have agreed to its terms. Prodigy Finance loans are offered to eligible borrowers and these loans are governed by English law.
Prodigy Services Limited is incorporated in the United Kingdom (Company Number 10201413) with its registered address at Palladium House 1-4 Argyll Street, London, W1F 7LD. Prodigy Services is an appointed representative of Sapia Partners LLP which is authorised and regulated by the Financial Conduct Authority. Prodigy Services Limited promotes offers of securities for third party issuers to eligible investors.