Privacy Notice

Privacy Notice

Who we are
Amicus Group is made up of a number of different legal entities. We’ll let you know which you have a relationship with, when you take out a product or service with us.

How we use your personal information
This privacy notice lets you know how companies within the Amicus Group promise to look after your personal information. This includes what you tell us about yourself, what we learn by having you as a customer, and the choices you give us about what marketing you want us to send you. This notice explains how we do this and tells you about your privacy rights and how the law protects you.

How the law protects you
Your privacy is protected by law. This section explains how that works. Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside the Amicus Group. The law says we must have one or more of the following reasons:

• To fulfil a contract we have with you, or
• When it is our legal duty, or
• When it is in our legitimate interest, or
• When you consent to it.

A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.

Here is a list of all the ways that we may use your personal information, and which of the reasons we rely on to do so. This is also where we tell you what our legitimate interests are.

What we use your personal information for:
• To manage our relationship with you or your business.
• To develop new ways to meet our customers’ needs and to grow our business.
• To undertake statistical analysis and systems testing.
• To develop and carry out marketing activities.
• To develop and manage our brands, products and services.
• To manage how we work with other companies that provide services to us and our customers.
• To deliver our products and services.
• To make and manage customer payments.
• To manage fees, charges and interest due on customer accounts.
• To collect and recover money that is owed to us.
• To detect, investigate, report, and seek to prevent financial crime.
• To manage risk for us and our customers.
• To obey laws and regulations that apply to us.
• To respond to complaints and seek to resolve them.
• To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, communications, corporate governance, and audit.
• To manage the funding arrangement of your loan with Amicus funding providers.
• To exercise our rights set out in agreements or contracts.

Our reasons:
• Your consent.
• Fulfilling contracts.
• Our legitimate interests.
• Our legal duty. Our legitimate interests:
• Keeping our records up to date, working out which of our products and services may interest you and telling you about them.
• Developing products and services, and what we charge for them.
• Defining types of customers for new products or services.
• Seeking your consent when we need it to contact you.
• Being efficient about how we fulfil our legal duties.
• To enable us to fulfil our legal and contractual duties.
• Complying with regulations that apply to us.
• Developing and improving how we deal with financial crime, as well as doing our legal duties in this respect.
• Complying with regulations that apply to us.
• Being efficient about how we fulfil our legal and contractual duties.

Groups of Personal Information
We use many different kinds of personal information, and group them together like this, with the type and description below.
*Financial: Your financial position, status and history.*
*Contact: Where you live and how to contact you.
Contractual: Details about the products and services we provide to you.
Communications: What we learn about you from letters, emails, customer meetings and conversations between us.
Open Data and Public Records: Details about you that are in public records, such as the Electoral Register, and information about you that is openly available on the internet.
Documentary Data: Details about you that are stored in documents in different formats, or copies of them. This could include things like your passport, drivers licence or birth certificate.
Special types of data: The law and other regulations treat some types of personal information as special. We will only collect and use these types of data if the law allows us to do so:* Criminal convictions and offences
*Consents: Any permissions, consents or preferences that you give us. This includes things like how you want us to contact you or if you prefer large-print formats.*
*National Identifier: A number or code given to you by a government to identify who you are, such as a National Insurance number.*

Where we collect personal information from
We may collect personal information about you and/or your business from other companies within the Amicus Group and from these sources:
Data you give to us:
• When you apply for our products and services
• When you talk to us on the phone
• When you talk to us in a video recorded client interview
• When you use our websites
• In emails and letters
• In financial reviews and interviews
• In customer surveys

Data from third parties we work with:
• Companies that introduce you to us
• Financial advisers
• Credit reference agencies
• Fraud prevention agencies
• Land agents
• Public information sources such as Companies House
• Agents working on our behalf
• Government and law enforcement agencies

Who we share your personal information with
We may also share your personal information if the make-up of the Amicus Group changes in the future:
• Agents and advisers who we use to help us run your accounts and services, collect what you owe, and explore new ways of doing business
• HM Revenue & Customs, regulators and other authorities
• Credit reference agencies
• Fraud prevention agencies
• If you have a secured loan or mortgage with us, we may share information with other lenders who also hold a charge on the property
• Any party linked with you or your business’s product or service
• Companies we have a joint venture or agreement to co-operate with
• Organisations that introduce you to us
• Companies that we introduce you to
• Companies you ask us to share your data with

We may also share your personal information if the make-up of the Amicus Group changes in the future:
• We may choose to sell, transfer, or merge parts of our business, or our assets. Or we may seek to acquire other businesses or merge with them.
• During any such process, we may share your data with other parties. We’ll only do this if they agree to keep your data safe and private.
• If the change to our Group happens, then other parties may use your data in the same way as set out in this notice.

Credit Reference Agencies
We carry out credit and identity checks when you apply for a product or services for you or your business. We may use Credit Reference Agencies to help us with this.

If you use our services, from time to time we may also search information that the CRAs have, to help us manage those accounts.

We will share your personal information with CRAs and they will give us information about you. The data we exchange can include:
• Name, address and date of birth
• Credit application
• Details of any shared credit
• Financial situation and history
• Public information, from sources such as the electoral register and Companies House

We’ll use this data to:
• Assess whether you or your business is able to afford to make repayment(s)
• Make sure what you’ve told us is true and correct
• Help detect and prevent financial crime
• Manage accounts with us
• Trace and recover debts
• Make sure that we tell you about relevant offers

We will go on sharing your personal information with CRAs for as long as you are a customer. This will include details about your settled accounts and any debts not fully repaid on time. It will also include details of funds going into the account, and the account balance. If you borrow, it will also include details of your repayment(s) and whether you repay in full and on time. The CRAs may give this information to other organisations that want to check credit status. We will also tell the CRAs when you settle your accounts with us.

When we ask CRAs about you or your business, they will note it on your credit file. This is called a credit search. Other lenders may see this and we may see credit searches from other lenders.

If you apply for a product with someone else, we will link your records with theirs. We will do the same if you tell us you have a spouse, partner or civil partner – or that you are in business with other partners or directors.

You should tell them about this before you apply for a product or service. It is important that they know your records will be linked together, and that credit searches may be made on them.

CRAs will also link your records together. These links will stay on your files unless one of you asks the CRAs to break the link. You will normally need to give proof that you no longer have a financial link with each other.

You can find out more about the CRAs on their websites, in the Credit Reference Agency Information Notice. This includes details about:
• Who they are
• Their role as fraud prevention agencies
• The data they hold and how they use it
• How they share personal information
• How long they can keep data
• Your data protection rights

Here are links to the information notice for each of the three main Credit Reference Agencies:
Callcredit - www.callcredit.co.uk/crain
Equifax - www.equifax.co.uk/crain
Experian - www.experian.co.uk/crain/index.html

Fraud Prevention Agencies (FPAs)
Before we provide products, services or financing to you or your business we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity.

Both we and fraud prevention agencies can only use your personal information if we have a proper reason to do so. It must be needed either for us to obey the law, or for a ‘legitimate interest’.

A legitimate interest is when we have a business or commercial reason to use your information. This must not unfairly go against what is right and best for you.

We will use the information to:
• Confirm identities
• Help prevent fraud and money-laundering
• Fulfil any contracts you or your business has with us

We or an FPA may allow law enforcement agencies to access your personal information. This is to support their duty to detect, investigate, prevent and prosecute crime.

FPAs can keep personal information for different lengths of time. They can keep your data for up to six years if they find a risk of fraud or money-laundering.

The information we use
These are some of the kinds of personal information that we use:
• Name
• Date of birth
• Residential address and address history
• Contact details, such as email addresses and phone numbers
• Financial information
• Employment details
• Identifiers assigned to your computer or other internet connected device including your Internet Protocol (IP) address
• Vehicle details
• Data relating to your or your businesses products or services

How this can affect you
If we or an FPA determine that you pose a fraud or money laundering risk, we may refuse to provide the services and financing you have requested or we stop providing existing services to you.

FPAs will also keep a record of the risk that you or your business may pose. This may result in other organisations refusing to provide you with products or services, financing or to employ you.

Data transfers
FPAs may send personal information to countries outside the European Economic Area (‘EEA’). When they do, they will impose contractual obligations on the recipients to protect your personal data to the standard required in the EEA. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.

If you choose not to give personal information
We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime, or under the terms of a contract we have with you.

If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services needed to run your account(s). It could mean that we cancel a product or service you have with us.

Any data collection that is optional would be made clear at the point of collection.

How to get a copy of your personal information
You can access your personal information we hold by emailing us at dataprotection@amicusasf.co.uk.

Letting us know if your personal information is incorrect
You have the right to question any information we have about you that you think is wrong or incomplete. Please contact us if you want to do this. If you do, we will take reasonable steps to check its accuracy and correct it. What if you want us to stop using your personal information?

You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.

There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.

We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights. In this situation, we would not use or share your information in other ways while it is restricted.

You can ask us to restrict the use of your personal information if:
• It is not accurate.
• It has been used unlawfully but you don’t want us to delete it.
• It’s not relevant any more, but you want us to keep it for use in legal claims.
• You have already asked us to stop using your data but you are waiting for us to tell you if we are allowed to keep on using it.

If you want to object to how we use your data, or ask us to delete it or restrict how we use it, please contact us at dataprotection@amicusaf.co.uk.

Formats for sharing data
You have the right to get your personal information from us in a format that is readily accessible.

Marketing
We may use your personal information to tell you about relevant products and offers. This is what we mean when we talk about ‘marketing’.

We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you.

You can ask us to stop sending you marketing messages by contacting us at any time.

Whatever you choose, you’ll still receive statements, and other important information such as changes to your existing products and services.

We may ask you to confirm or update your choices, if you take out any new products or services with us in future. We will also ask you to do this if there are changes in the law, regulation, or the structure of our business.

If you change your mind you can update your choices at any time by contacting us.

How to withdraw your consent
You can withdraw your consent at any time. Please contact us at dataprotection@amicusaf.co.uk or call us on 020 3893 9000 if you want to do so.

If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.

How long we keep your personal information
We will keep your personal information for as long as you are a customer of Amicus Group.

After you stop being a customer, we may keep your data for up to six years for one of these reasons:
• To respond to any questions or complaints.
• To show that we treated you fairly.
• To maintain records according to rules that apply to us.

We may keep your data for longer than six years if we cannot delete it for legal, regulatory or technical reasons. If we do, we will make sure that your privacy is protected and only use it for those purposes.

If you are unhappy
Please let us know if you are unhappy with how we have used your personal information by emailing us at dataprotection@amicusaf.co.uk or calling us on 020 3893 9000.

You also have the right to complain to the Information Commissioner’s Office. Find out on their website how to report a concern - https://ico.org.uk/concerns.