Betterpace Limited trading as V5Solutions.co.uk ("the Company" "we", "us" and "our") is a company registered in England and Wales under company registration number 03164518, having its registered office 89 Bridge Road, Oulton Broad, Lowestoft, Suffolk, NR32 3LN.
The Company is authorised and regulated by the Financial Conduct Authority with Interim Permission Number 414684 to provide personal loans and other financial services to consumers in the UK.
This Policy (together with our Website Terms and Conditions of Use) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. The Company is registered with the Information Commissioner's Office with registration number Z6944371 and will act as Data Controller in accordance with the provisions of the Act.
PLEASE READ THE FOLLOWING CAREFULLY TO UNDERSTAND HOW WE ACQUIRE, PROCESS AND STORE YOUR PERSONAL DATA AND YOUR RIGHTS OF ACCESS.
2. Information we may collect from you
2.1 We may collect and process the following data about you:
2.1.1 Information that you may provide by filling in the forms on V5Solutions.co.uk (our "Site"). This includes information provided at the time when you complete a loan application form on our Site, or any other information you provide to us in the course of our business dealings with you.
2.1.2 Information obtained from you or from third parties, such as Credit reference agencies ("CRAs") (who may search the Electoral Register), fraud prevention agencies ("FPAs") or other organisations when you apply for a loan or any other product or service or which you or they give to us at any other time.
2.1.3 Details of transactions you carry out through our Site and of the fulfilment of your loan(s) or other financial products we may offer, and the way you manage your account.
2.1.4 Correspondence and records of all contact with you, including any discussions; please note that calls between us may be recorded and/or monitored.
2.1.5 Surveys that we use for research purposes, which we may ask you to complete, although you are under no obligation to respond.
2.1.7 Information from third parties in respect of you which may include your employer, a referee or a person residing or working from another country.
3. How we use your information
3.1 The Company collects and processes your data in order to provide you with access to short term personal loans and other financial services and to help to prevent fraud and money laundering.
3.2 We use information held about you in the following ways, namely to:
3.2.1 process your application;
3.2.2 assess your credit worthiness and loan affordability;
3.2.3 verify your identity and the identity of your spouse, partner or other directors/partners;
3.2.4 apply scoring methods to assess this application;
3.2.5 manage your account and make collections;
3.2.6 provide statements detailing activity on your account;
3.2.7 develop, improve and update our products and services;
3.2.8 conduct statistical analysis;
3.2.9 notify you about changes to our service;
3.2.10 provide you with information about goods and services which may be of interest to you and we may contact you about these by post, telephone, email, SMS or reasonable method ;
3.2.11 with your consent, permit selected third parties to provide you with information about goods and services which may be of interest to you (for example if we cannot provide you with the product or service you request and another party may be able to provide something similar) they may contact you by post, telephone, email, SMS or other reasonable method.
3.3 If you are making a joint application or tell us that you have a spouse or financial associate we will:
3.3.1 link any individual identified as your financial associate, in our own records.
3.3.2 take both your and their information into account in future applications by either or both of you.
3.3.3 continue this linking until the account closes, or is changed to a sole account and one of you notifies us that you are no longer linked.
3.4 Your data may also be used for other purposes for which you give your specific permission or, in very limited circumstances, when required by law or where permitted under the terms of the Act.
4. Storing your personal data
4.1 We will store and process your information securely as we deem appropriate, for example on our computers and servers for a reasonable period at least for the period required by law.
4.2 All information you provide to us is, as far as reasonably practicable, stored on our secure servers. We ask you not to permit anyone to use your name.
4.3 In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. Further information is provided below under heading 5 'Security'.
5.1 When you enter our Site after the first occasion and want to retrieve your valuation, we will check your identity by asking for your vehicle registration and the PIN that was sent to your mobile. As long as the correct Registration and PIN are entered, we will assume that you are the person giving instructions and making transactions and you will be liable for those transactions.
5.2 You must never tell another individual your PIN (nor other codes that protect access to your account) or write them down without disguising them.
5.3 You must tell us immediately if you suspect that someone else knows your PIN that protects access to your account with the Company by impersonating you. Until you tell us:
(a) you will be responsible for any instruction which we receive and act on, even if it was not given by you; and
(b) we will not be responsible for any unauthorised access to confidential information about you on our website.
5.4 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorized access.
5.5 Our site may, from time to time, contain links to and from the websites of our advertisers and 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 data to these websites.
6. Disclosure of your information
6.1 We may disclose your personal information to third parties:
6.1.1 to process your loan application, or any of the services you have requested;
6.1.2 to prepare or send any communications to you;
6.1.3 to assist us in connection with any of our administrative or business functions, or in the provision of any of our services to you;
6.1.4 if the Company or substantially all of its assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
6.1.5 If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions of Use and other agreements; or to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
6.2 We may give information about you and how you manage your account to the following:
6.2.1 law enforcement agencies in circumstances where we are required to do so by law;
6.2.2 persons and legal entities which provide a service to us or are acting as our agents, on the understanding that they will keep the information confidential; and
6.2.3 CRAs and FPAs (see Clause 10 below).
7. An explanation of what cookies are and how we use them
7.1 A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps web applications to respond to you as an individual by gathering and remembering information about your preferences and which pages you visit. Some cookies only exist whilst users are online but persistent cookies – which are not session-based – remain on the user's computer, so that he or she can be recognised as a previous visitor when he or she next visits our website. A cookie in no way gives us access to your computer or any information about you, other than the information you choose to share with us.
7.3 The Company does not store sensitive information such as account numbers or passwords in persistent cookies, and cookies in themselves, do not contain enough information to identify you.
7.4 In addition to using cookies, wealso use web tools to collect information about your browsing activities whilst on our website. In this respect the information that is provided is similar to the information supplied by cookies, and we use it for the same purpose.
7.5 Any information that we acquire about you using cookies [or web tools] is subject to the same restrictions and conditions as any other information we collect about you.
8. Promotional and marketing communications
8.1 You may opt-out of receiving promotional emails and marketing communications from us by ticking the appropriate box on the loan application form on our Site, or at any time by responding to any of our email communications with "remove" in the subject line, by sending us an email to firstname.lastname@example.org or by contacting us at Betterpace Limited trading as V5Solutions.co.uk, 27 St. Benedicts Street, Norwich, Norfolk, NR2 4PF. We reserve the right to take reasonable steps to authenticate your identity with respect to any such request or other enquiry.
8.2 If you opt-out of our use of your data for marketing purposes, we will honour such choice once we have had a reasonable opportunity to process your request.
9. Your rights
9.1 You have the right, under section 7 of the Act, to access information held about you. Your right of access can be exercised in accordance with the Act by writing to us at email@example.com or Betterpace Limited trading as TopUpToday.co.uk, 27 St. Benedicts Street, Norwich, Norfolk, NR2 4PF. Any access request may be subject to a small statutory fee to meet our costs in providing you with details of the information we hold about you.
10. Credit reference and fraud prevention
10.1 When you apply for a loan or other financial product we may offer, you confirm that all the information you have given is true and complete. You authorise us to check the following records about you and others:
(a) our own;
(b) those at CRAs; and
(c) those at FPAs.
10.2 We will make checks such as assessing your loan application for credit worthiness and loan affordability in accordance with our responsible lending policy (see Clause 11 below). We may also make periodic searches at CRAs and FPAs to verify your identity and to manage your account with us.
10.3 Information on loan applications and details of your agreement(s) with us and any default or suspected fraud will be sent to CRAs and FPAs and will be recorded by them. This information may be supplied to other organisations by CRAs and FPAs and may be used and searched by us and other organisations in order to:
10.3.1 consider applications for credit and credit related services such as insurance for you and any associated person;
10.3.2 prevent or detect money laundering and fraud;
10.3.3 trace debtors or recover debts;
10.3.4 manage your accounts.
10.4 Records remain on file with CRAs and FPAs for 6 years after they are closed, whether settled by you or defaulted.
10.5 You have a right to be told which Credit Reference Agency we use and to obtain from the Agency a copy of your file. Some of the CRAs we use are listed below [Insert the CRAs that you will be using:
10.6 For full written details of how your data may be used please contact the agencies below (they will charge you a small statutory fee).
10.6.1 Equifax PLC, Credit File Advice Centre, PO Box 3001, Bradford, BD1 5US or call 0870 010 0583 or visit www.myequifax.co.uk
10.6.2 Experian Consumer Help Service, PO Box 8000, Nottingham NG80 7WF or call 0870 241 6212 or visit www.experian.co.uk.
11.1 By using our Site you consent to our collection and use of your personal information as described in this Policy. We reserve the right to amend this Policy at any time with or without notice. Any changes we may make to our Policy in the future will be posted on this page.
12.1 Questions, comments and requests regarding this Policy are welcomed at firstname.lastname@example.org or Betterpace Limited trading as V5Solutions.co.uk, 42-44 St. Benedicts Street, Norwich, Norfolk, NR2 4AQ.
12.2 If you have any concerns about the information we hold you should contact the Data Protection Officer at the Company stating what you think the problem is and you will get a response within 10 working days. If you still feel dissatisfied, you can appeal to the Managing Director of the Company or you can contact the Information Commissioner's Office by writing to the Customer Services Team, Wycliffe House, Water Lane, Wilmslow SK9 5AF; or by calling 0303 123 1113.Consumer Credit Trade Association