Privacy Policy - Archive - Prodigy Finance

Effective Date: 19 January 2018

Introduction

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.

This privacy policy (“Privacy Policy”) sets out the basis on which we will process, store, and disclose any personal data we collect from you or that you provide to us in connection with the website owned and operated by Prodigy Finance, https://prodigyfinance.com (“Site”), or in connection with the products and services that we offer, including loans (“Services”). By using the Site, you signify that you have read, understand, and agree to be bound by the Privacy Policy, regardless of whether you have registered to use any of our Services. Please read the Privacy Policy very carefully. If you do not wish to be bound by Privacy Policy, you should not access or use the Site or Services.

This Privacy Policy may change from time to time. Any changes we may make to our Privacy Policy in the future will be posted on this page. Unless otherwise stated, any updates to this Privacy Policy become effective when we post the updates on the Site. Your use of the Site or Services following an update to the Privacy Policy means that you accept the updated Privacy Policy.

Table of Contents

2. What Personal Information we collect

Prodigy Finance acts as a lender, loan broker, and administrator of loans. In the United Kingdom it acts as a consumer credit broker and administers loans on behalf of MBA Community Loans plc (a public limited company with limited liability incorporated under the Companies Act 1963 (as amended) of Ireland with number 486917), through which alumni, universities, and others who finance the loans Prodigy Finance makes available to students (the “Lenders”) invest in the loans that we make

Prodigy Finance may collect and process the following information about you (together “Personal Information”) through your use of the Site or Services:

Information that you provide by filling in forms on our Site, which may include Personal Information provided at the time of registering for an account, subscribing to our Services, posting material, or requesting further Services or any Personal Information we request when you report a problem with our Site;
Information about your income, account balances, or payment history;
Your contact details, including your email address, physical address, telephone numbers, and (where applicable) the contact details of your next of kin;
Copies of passports or other identification evidence that you provide;
A photograph that you provide;
Records of any correspondence between you and us;
Records of any surveys that we may ask you to complete that we use for research purposes, although you do not have to respond to them;
Details of transactions you carry out through our Site and of the fulfilment of your loan repayments;
Your citizenship or country of residence or similar information;
Information relating to any criminal proceedings in which you have been involved;
Credit checks to comply with obligations to assess your creditworthiness;
Information relating to your performance of any obligations under any loan we make to you; and
Any other information that you choose to provide to us or that you consent to us collecting.

This Personal Information 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 information about you from third parties in connection with our Services (for example, a credit reporting agency).

Please note that you are not required to provide any Personal Information for publication on the public areas of our Site.

4. Cookies

A “cookie” is information that a website stores on your machine so that it can remember something about you at a later time. Cookies are commonly used on the Internet and do not harm your system. Most Internet browsers are initially set up to accept cookies, but if desired you can choose to not accept some cookies through your browser settings.

We use cookies to track how our customers use our site in order to provide a more relevant experience and to improve our service. We use:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.

Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

The information stored in our cookies is kept separate from your Personal Information and will never be used in combination with your Personal Information. You can reset your Internet browser to refuse all cookies or to warn you before accepting cookies. For more information on how to do this, visit https://www.consumer.ftc.gov/articles/0042-online-tracking. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Site.

5. Where we store your Personal Information

Your Personal Information is generally stored in the United Kingdom, but it may also be transferred to, and stored at, a destination outside the European Economic Area ("EEA") for processing by our service providers or by service providers of Lenders or our partners. Personal Information from users based in the U.S. will not be stored in the U.S. and will be transferred to, and stored at, a destination outside the U.S. Such processing may include the processing of your payment details and the provision of support services (such as with regard to credit checks, debt collection, etc.). By submitting your Personal Information, you agree to this transfer, storing, or processing. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy.

Once we have received your Personal Information, we will use reasonable procedures and security features to try to prevent unauthorized access. However, the transmission of information via the Internet is not completely secure and, while we will do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Site; any transmission is at your own risk.

6. How we use your Personal Information

Prodigy Finance acts as a data controller when using your Personal Information in providing you with Services and as a data processor on behalf of Lenders.

We use Personal Information held about you in the following ways:

To ensure that content from our Site is presented in the most effective manner for you and for your computer;
To provide you with information about our Services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
For statistical analysis or market research;
To develop and improve our Services;
To update our records;
To identify which of our, or others', products or services might interest you;
To assess lending and insurance risks;
To arrange, underwrite, and administer insurance and handle claims;
To detect, investigate, prevent, or tackle illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person;
To ensure our compliance with applicable laws and regulations;
To carry out our obligations arising from and exercise our rights under any agreements between you and us;
To allow you to participate in interactive features of our Services, when you choose to do so;
To notify you about changes to our Services;
To provide you with customer service;
For any legitimate business purpose permitted by law; and
In any other way that you have specifically consented to.

7. Disclosure of your Personal Information

We may disclose your Personal Information 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 EEA, or elsewhere.

Prodigy Finance will keep your Personal Information confidential and only disclose it to others for the purposes described in this Privacy Policy, including:

In connection with a merger, acquisition, consolidation, change of control, sale of all or a portion of our assets, if we undergo bankruptcy or liquidation, or in connection with any other corporate change;
In our discussions with potential Lenders or investors, in which case we may disclose your Personal Information to such prospective Lenders or investors;
If we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation; in order to enforce or apply any agreements we have entered with you; or to protect the rights, property, or safety of Prodigy Finance, our customers, or others, including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;
If you request or give your permission for us to do so;
To a credit reporting agency or other third-party service provider to check your identity and to prevent fraud;
To tell credit reporting agencies that you have an account and how you run that account;
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 investigate, prevent, or detect fraud, money laundering, or other illegal activities;
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.

8. Fraud prevention agencies and credit agencies

If you are attending a school outside the United States and are not a United States resident at the time of making the loan application, then the following provisions apply. Prodigy Finance will check your details with a fraud prevention agency/agencies, and if you give false or inaccurate information and Prodigy Finance identifies fraud, this will be recorded. Prodigy Finance and other organizations, including law enforcement agencies and debt collection agencies, may access, use, and search these records to:

help make decisions about credit and credit-related services, for you and members of your household;
help make decisions on motor, household, credit, life and other insurance proposals, and insurance claims, for you and members of your household;
trace debtors, recover debt, prevent fraud, and to manage your accounts or insurance policies;
prevent 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;
checking details on proposals and claims for all types of insurance; and
checking details of job applicants and employees.

Please contact us at info@prodigyfinance.com if you want to receive details of the relevant fraud prevention agencies.

Any credit reference agency Prodigy Finance searches 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 Information

You have the right to ask us not to process your Personal Information for marketing purposes. The manner in which we use Personal Information for marketing purposes in the United States is set out in our Privacy Notice. We will usually inform you (before collecting your Personal Information) if we intend to use your Personal Information for such purposes or if we intend to disclose your Personal 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 use to collect your data. You can also exercise the right at any time by contacting us at info@prodigyfinance.com.

Prodigy Finance aims to keep your Personal Information accurate and up-to-date. You may access, correct, delete, or modify the Personal Information that you provided to us and associated with your account. Access requests may be subject to a fee to meet our costs in providing you with details of the Personal Information we hold about you in accordance with the provisions of the Data Protection Act 1998. Please advise us of any changes by emailing info@prodigyfinance.com or by updating your profile online on https://prodigyfinance.com.

10. Third party data collection and links to other websites

Some content or applications on the Site are provided by third parties, including analytics companies and advertising providers. Our Site also includes social media features, such as the Facebook “Like” button, and other widgets, such as the “Share” button or interactive mini-programs provided by third parties. These third parties may use cookies or other tracking technologies to collect information about you when you use our Site. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services.

We may use third-party service providers that collect information about users over time and across different websites in order to serve advertisements on our behalf that are more targeted and relevant to your interests. Prodigy Finance complies with the Digital Advertising Alliance ("DAA") Principles for Online Behavioral Advertising. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly, such as by clicking on the "Ad Choices" icon in or around the advertisement. The DAA provides a single location where you can opt out of certain types of data collection and use or out of receiving targeted ads from member companies. To opt out, please visit www.aboutads.info to exercise choice with respect to participants of the DAA.

We also use Google Analytics, which is a service provided by Google. Google utilizes the data collected to track and examine the use of our Site and may share this data with other Google services. You can learn more about Google’s privacy practices by visiting their website at http://www.google.com/policies/privacy/partners/.

Similarly, our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers, or affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Information to these websites.

11. 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.

As part of your loan application, you will be asked to agree to the terms of this Privacy Policy and other Personal Information collection, use, and disclosure provisions specific to the Services you receive. In particular, you will be asked to authorize (a) Prodigy Finance to request Personal Information from your university relating to you for the purpose of originating and servicing your loan; and (b) your university to disclose to Prodigy Finance any Personal Information relating to you that Prodigy Finance validly requests for the purpose of originating and servicing your loan.

14. Contact

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 Information 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.

If you have any questions regarding this Privacy Policy, please email us at info@prodigyfinance.com.

© Prodigy Finance Limited 2007 - 2020. 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.