Your personal information and how we use it
How we collect your personal information
Legal basis for processing your personal information
Sharing your personal information
Your legal rights
Links to other websites
Contact details and how to make a complaint
Your rights to object: You have various rights in respect of our use of your personal information as set out in section 7 LINK. Two of the fundamental rights to be aware of are that:
- You may ask us to stop using your personal information for direct marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.
- You may ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our, or another person’s, legitimate interest.
You can find out more information in section 7.
Your personal information and how we use it
Personal data, or personal information, means any information about a living individual from which that person can be identified. We refer to this as “personal information” throughout this policy. It does not include data where the identity has been removed (anonymous data).
Throughout this policy, we refer to both the website and the portal as the “website”.
We, or third parties on our behalf, may collect and use any of the following information about you:
- your name including your title
- your postal address
- your email address
- your telephone number
- your employment history
- your financial details, including savings and salary
- your credit score and loan repayment history
- information necessary to complete the loan application process
- information on your investing history and investment portfolio
- information provided when you correspond with us
- any updates to the information provided to us
- personal information we collect about you or that we obtain from our third-party sources
The following information is created and recorded automatically when you visit our website:
Technical information. This includes the Internet Protocol (IP) address used to connect your computer to the internet address; the website address and country from which you access information; the files requested; browser type and version; browser plug-in types and versions; operating system; and platform. We use this personal information to administer our website, measure the efficiency of our systems, and to undertake an analysis of the locations from which people access our web pages;
Information about your visit and your behavior on our website (for example, the pages that you click on). This may include the website you visit before and after visiting our website (including date and time), time and length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, traffic data, location data, weblogs and other communication data and information provided when requesting further service or downloads.
We will collect, use and store the personal information listed above for one or more of the following reasons:
(i) to allow you to access, use and make loan applications via our website
(ii) to receive inquiries from you through the website;
(iii) for improvement and maintenance of our website and to provide technical support for our website
(iv) to ensure the security of our website
(v) to recognize you when you return to our website, to store information about your preferences, and allow us to customize the website according to your individual interests; and
(vi) to evaluate your visit to the website and prepare reports or compile statistics to understand the type of people who use our website, how they use our website, and to make our website more intuitive. Such details will be anonymized as far as reasonably possible and you will not be identifiable from the information collected.
A word about cookies
(iii) For detailed information on the cookies we use and the purposes for which we use them, please refer to our cookies policy here.
Aggregated data. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal information but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
Special categories of data. We do not collect any Special Categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) except in extreme circumstances such as death or a medical illness and only where we have notified you and there is a legal basis for us to do so.
Whatever our relationship with you is, we may also collect, use and store your personal information for the following additional reasons:
(a) to deal with any inquiries or issues you have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for customer services purposes;
(b) for internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies. We may process your personal information for these purposes where it is in our legitimate interests to do so;
(c ) to comply with any procedures, laws, and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so;
(d) to establish, exercise, or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so; and
Before using your personal information for any purposes which fall outside those set out in this Section 1 we will undertake an analysis to establish if our new use of your personal information is compatible with the purposes set out in this Section 1. Please contact us using the details in section 12 if you want further information on the analysis we will undertake.
How we collect your personal information
Most of the personal information we process is provided to us directly by you for one of the following reasons:
- You have applied for one of our products;
- You have created an account on our website;
- You have completed online forms (including call back requests);
- You have requested marketing information to be sent to you;
- You have entered a competition, promotion, or survey;
- You have interacted with us using social media;
- You have applied for employment with us;
- You have applied to be an Ambassador;
- You have registered your interest in investing;
- You are personnel at one of our school partners;
- You are personnel at one of our referral partners;
- You are seeking to become a referral partner; or
- You have given us feedback or contacted us
We will also collect information from your devices (including mobile devices) and applications you use to access and use our website, portal, applications or services. We may do this using cookie or similar technologies (described further below).
We may enhance the personal information we collect from you with information we obtain from third parties that are entitled to share that information, for example:
Technical data from analytics providers, advertising networks, and search information providers;
Contact, financial, and transaction data from providers of technical, payment, credit rating, and delivery services; and
Identity and contact data from publicly available sources including social media.
VISITORS TO OUR WEBSITE
When you visit our website, we use third-party services to collect standard internet log information and details of visitor behavior patterns. We do this to find out such things as the number of visitors to the various parts of the site.
This information is only processed in a way that does not directly identify anyone. We do not make and do not allow Google to make, any attempt to find out the identities of those visiting our website.
Cookies and similar technologies
Cookies can be managed via activating settings on your browser.
Cookies that are necessary for functionality, security, and accessibility are set and are not deleted by the tool.
Do Not Track
Our website is not currently configured to respond to Do Not Track signals sent by internet browsers.
Legal basis for processing your personal information
- Where our use of your personal information is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Our legitimate interests are to:-
- operate our website, portal, and app;
- carry out internal administration;
- perform data analytics and benchmarking;
- carry out direct marketing (where you are a business user or you have provided “soft opt-in” (see section 5 below);
- maintain automated backup systems;
- detect and prevent crime;
If we rely on our legitimate interests for using your personal information, we will undertake a balancing test to ensure that our legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information. You can ask us for information on this balancing test by using the contact details at section 12).
- Where our use of your personal information is necessary to comply with a legal obligation.
- Where you have given clear consent for us to process your personal information for a specific purpose. We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time after giving it, as described below LINK).
- If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by contacting us at firstname.lastname@example.org and we will stop doing so. However, if you withdraw your consent, this may impact our ability for us to be able to provide our services to you.
Sharing your personal information
We may share your personal information with our group companies where it is in our legitimate interests to do so for internal administrative purposes (for example, for corporate strategy, compliance, auditing, and monitoring, research and development, and quality assurance).
We may share your personal information with the following third parties or categories of third parties:
- Our service providers and agents or third parties which may process the information on our behalf (e.g. internet service and platform providers, payment processing providers, and identification verification providers);
- Partners that may help us to provide you with the products, services, and information you have requested or which we believe are of interest to you;
- Third parties to facilitate payment transactions;
- Third parties for marketing purposes, including our referral partners;
- Credit reference, credit reporting, and fraud prevention agencies;
- To a third-party service provider for the purpose of obtaining or verifying a particular category of information, including for example your academic records, Graduate Management Admission Test (GMAT) score, and contact information;
- To our service providers or Lenders’ service providers, whose services may include any part of the origination or lending process, operating the lending and collections business, or obtaining payments under the loan;
- To a loan broker in the event that Prodigy Finance is not able to provide you with the Services you applied for, and Prodigy Finance reasonably believes that the loan broker may be able to help you obtain a loan;
- For audit purposes and to meet obligations to any relevant regulatory authority or taxing authority; and
- To search engines and social profile networks for advertising and marketing purposes.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
We will also disclose your personal information to third parties:
where it is in our legitimate interests to do so to run, grow and develop our business:
where you request or give your permission for us to do so;
to share and confirm the with a school or university details of your loan application(s) or loan/(s) with us;
if we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets;
if substantially all of our or any of our affiliates’ assets are acquired by a third party, in which case personal information held by us will be one of the transferred assets;
where we transfer our agreement with you to a third party;
in our discussions with potential lenders or investors;
if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials, and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
to protect the rights, property, or safety of Prodigy Finance, our staff, our customers, or other persons.
We may also disclose and use anonymized, aggregated reporting and statistics about users of our website and services for the purpose of internal reporting or reporting to our group or other third parties, and for our marketing and promotion purposes. None of these anonymized, aggregated reports or statistics will enable our users to be personally identified.
Save as expressly detailed above, we will never share, sell or rent any of your personal information to any third party without notifying you and, where necessary, obtaining your consent. If you have given your consent for us to use your personal information in a particular way, but later change your mind, you should contact us and we will stop doing so.
Prodigy Finance may communicate with your university to verify your most recent physical address and contact details during the servicing of your loan.
Where you respond to communications we post on third-party platforms (such as LinkedIn, Instagram, Facebook, Google, and Twitter), we may also share your information with those third parties in order to serve targeted advertising/content to you via the relevant third-party platform based on your profile/interests. Your information is used by the third-party platform provider to identify your account and serve advertisements to you. You can control what advertisements you receive via the privacy settings on the relevant provider’s platform and you should consult their help/support center for more information.
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 information 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:
- assess your creditworthiness and whether you can afford a Prodigy Finance loan or related service;
- verify the accuracy of the data you have provided to us;
- prevent criminal activity, fraud and money laundering for example, when:
- checking details on applications for credit and credit related or other facilities;
- managing credit and credit-related accounts or facilities; and
- checking details of job applicants and employees;
- manage your account(s);
- trace and recover debts; and
- ensure any offers provided to you are appropriate to your circumstances.
We will continue to exchange personal information 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 jurisdictions 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 information, data retention periods and your data protection rights with the CRAs are explained in more detail at the TransUnion website.
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.
We may collect and use your personal information for undertaking marketing by email, telephone and post.
We may send you certain marketing communications (including electronic marketing communications) if it is in our legitimate interests to do so for marketing and business development purposes (where you are (i) a business user; or (ii) you have purchased services from us before, or have substantially entered into negotiations to purchase services from us (“soft opt-in”) or if you have consented to receive such electronic marketing information.
We will always obtain your consent to direct marketing communications where we are required to do so by law and if we intend to disclose your personal information to any third party for such marketing.
If you wish to stop receiving marketing communications, you can contact us by email at email@example.com.
Your personal information may be used, stored and/or accessed by staff operating outside the United Kingdom and European Economic Area (‘EEA’) working for us, other members of our group, suppliers and other entities, as set out in section 4. Whenever we transfer your personal information out of the UK and/or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the UK Government in the case of transfers out of the UK, or by the European Commission in the case of transfers out of the EEA;
Where we use certain service providers, we may use specific contracts approved by the European Commission (or the UK Government for transfers out of the UK in due course). These contracts include certain safeguards to protect personal information.
It is important that you are aware that we transfer personal information to other countries including India and South Africa for processing. We have disclosed this fact to the ICO. Personal information from users based in the United States will not be stored in the United States and will be transferred to, and stored at, a destination outside the United States.
Further details on the steps we take to protect your personal information in these cases is available from us on request by contacting us by email at firstname.lastname@example.org at any time.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal information:
Right of access: by making a Data Subject Access Request (“DSAR”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Right to update your information: 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
Right to delete your information: This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. 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
Right to object: This enables you to prevent us from processing your personal information where we are relying on a legitimate interest (or those of a third party) or performance of a public task, and you want to object to the processing as you feel it impacts on your fundamental rights and freedoms. This is not an absolute right – in some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Right to stop marketing: You have an absolute right to ask us to stop using your personal information for direct marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.
Right to restrict the use of your information: This enables you to ask us to suspend the processing of your personal information in the following scenarios:
-If you want us to establish the data’s accuracy;
-Where our use of the data is unlawful but you do not want us to erase it;
-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;
-You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to data portability: We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated use of your personal information which you have provided consent for us to process or where we used the information to perform a contract with you.
If you wish to exercise any of the rights set out above, please contact us. We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example, if we need to keep using the information to comply with our own legal obligations or to establish, exercise, or defend legal claims.
If an exception applies, we will tell you this when responding to your request. We may request you provide us with the information necessary to confirm your identity before responding to any request you make.
You will not have to pay a fee to access your personal information (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 could refuse to comply with your request in these circumstances.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. We will do our best to protect your personal information but we cannot guarantee the security of your information which is transmitted to our website, applications, or services or to any other website, applications, and services via the internet or similar connection.
We will only retain your personal information for as long as reasonably necessary to fulfill the purposes we collected it for. The length of time for which we retain personal information depends on the purpose for which we collect and use it and/or as required to satisfy any legal, regulatory, tax, accounting, or reporting requirements, deal with a complaint or establish, exercise or defend our legal rights.
In some circumstances, you can ask us to delete your data, as set out above. In some circumstances, we will also anonymize your 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.
Links to other websites
Contact details and how to make a complaint
CONTROLLER’S CONTACT DETAILS
Prodigy Finance is the controller and responsible for your personal information, unless otherwise stated.
You are welcome to contact us by phone, email or post. More details can be found on our contact us page.
Full name of legal entity: Prodigy Finance Limited
Business address: Hardy House, 16-18 Beak Street, W1F 9RD, London
Telephone number: +44 20 7193 2832
DATA PROTECTION OFFICER’S CONTACT DETAILS
Email address: email@example.com
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. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.