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Our Privacy Policy

Any reference to we or us in this Privacy Policy is to WDFC UK Limited (in administration) (trading as Wonga). We are the data controller of any personal data we collect, which means we are responsible for complying with data protection laws.

We believe you deserve respect when it comes to the security and use of your personal data, so this Privacy Policy sets out details of the personal data we collect, why we use your personal data and, more generally, the ways in which we use your personal data, including how we look after your personal data. Please take your time to read this Privacy Policy carefully. When using our website this Privacy Policy should be read alongside our cookies policy at www.wonga.com/cookie-policy.

When we need to update this Privacy Policy to reflect any changes in how we use your personal data or where, from time to time, we need to make changes, for example as the result of new regulation, new technologies or other developments in data protection laws or privacy generally, we may provide you with an updated version of this Privacy Policy. You should also periodically check our website at www.wonga.com to view the most up-to-date version of this Privacy Policy. We provide you with the ability to opt-in or opt-out of marketing when we collect your personal data and while you have a relationship with us.

If you have any questions regarding our Privacy Policy or how we collect, store or use your personal data please contact us by email at [email protected], by phone 020 7138 8330 or by letter for the attention of the Data Protection Officer, WDFC UK Limited (in administration), The Harlequin Building, 65 Southwark Street, London, SE1 0HR.

1. Who do we collect information about?

We collect information about:

  • Users of our website
  • Individuals who open an account with us
  • Individuals who apply for a loan with us
  • Individuals who currently have a loan with us
  • Individuals who have previously taken out a loan with us

2. When do we collect your information?

We collect information about you:

  • When you use our website
  • When you open an account
  • When you apply for a loan
  • If you are late on loan payments
  • If you contact us or we contact you, for example to discuss repaying your loan, to change any of your details such as your address or your bank details, to complain or to exercise your rights in any redress programme

3. What information do we collect and use?

The information we collect depends on our relationship with you. We collect different information depending on whether you are a user of our website or whether you have opened an account, applied for a loan or taken out a loan.

Please note, in certain circumstances we may request or you may provide special categories of personal data about you, this includes information about your health, or personal data relating to criminal convictions and offences. For example, you may tell us about your health during discussions concerning the repayment of your loans.

We may collect the following personal data:

  • General personal information such as your name, gender, date of birth, residential address (and address history) and contact details such as your email address and telephone number (and any other telephone numbers you call from)
  • Information about your employment status, and where relevant your employer
  • Information relevant to your loan application, such as your home status, number of dependants and financial outgoings
  • Financial information such as your income, bank details, card details and current account transactional data
  • Information obtained as a result of searches at credit reference agencies and fraud prevention agencies
  • Information concerning the loans you have and have had with us and all transactional information relating to the payment (or non-payment) of those loans
  • Information obtained through our use of cookies. You can find more information about this in our Cookies Policy
  • Telephone recordings
  • Your marketing preferences
  • Identifiers assigned to your device such as your Internet Protocol (IP) address

We may also collect the following special categories of personal data and personal data relating to criminal convictions and offences:

  • Details of your current or former physical or mental health or where you receive disability payments
  • Information relating to criminal convictions, including offences and alleged offences and any court sentences or criminal convictions

4. How do we collect your information?

We collect information about you from many different sources including:

  • From you (or someone on your behalf) when:
    • viewing our website (via cookies)
    • using our website to open an account or apply for a loan
    • contacting us by email, social media, Live Chat or telephone (calls are recorded)
    • completing customer surveys
  • From third parties such as:
    • credit references agencies
    • fraud prevention agencies
    • service providers who:
      • help us check your identity and verify financial information so we can make appropriate credit-related decisions
      • help us monitor the ease of use of our website, online account opening process and application form so we can improve the user experience
      • help us monitor your use of social media to help us make appropriate credit-related decisions
      • help us carry out market research, surveys and business and statistical analysis
    • marketing companies who provide us with contact details such as name, address, email address and telephone number to help us target marketing campaigns to people who are not currently Wonga customers
    • your bank, for example if you change your bank and your old bank informs us of your new bank details

5. What are the purposes for which your personal data is used?

We mainly use your personal data to provide you with a loan and manage your account. However, we also process your personal data for many other different purposes. Under data protection laws, we need a specific reason every time we use your personal data and this is otherwise known as a legal ground. We rely on one or more of the legal grounds set out below when processing your personal data:

  • The processing is necessary for the provision and administration of your consumer credit agreement and for us to provide lending services, including assessing your application, managing your loan, collecting payments, recovering debts, making any amendments to your loan and providing other related services to you, such as resolving complaints
  • Where we have a legal or regulatory obligation to use your personal data, for example to comply with any laws or regulations that apply to us, or if the Financial Conduct Authority (FCA), Information Commissioner's Office (ICO), Competition and Markets Authority (CMA) or Financial Ombudsman Service (FOS) requires us to do something, such as comply with any redress programme, create or maintain certain records of any dealings with you, or disclose to them any records including your personal data.
  • Where we need to use your personal data for reasons of public interest, such as investigating fraudulent claims, carrying out fraud, credit and anti-money laundering checks and preventing other crimes.
  • Where we have an appropriate business need, otherwise referred to in data protection laws as 'legitimate interests', which could include running our company and internal operations, complying with our legal and regulatory obligations, evaluating your ability to pay back a loan, assessing whether another lender could more suitably lend to you, providing sustainable lending services, providing high quality and appropriate lending services, protecting our business by ensuring we have the correct information about you and preventing crimes (including fraud), administering loan repayments, recovering outstanding debts, maintaining our business records, developing, improving and marketing our products and services, improving the quality and security of our services, understanding and improving our business and services, ensuring our systems work as efficiently as possible, protecting the security of our systems, resolving complaints, maintaining customer satisfaction, complying with any redress programme and receiving professional advice. We only rely on this legal ground if the business need does not interfere with your rights and freedoms.

When the information we process is classed as a special category of personal data (such as details about your health) or personal data relating to criminal convictions and offences, we must have an additional legal ground for such processing and, in these circumstances, we will generally rely on the following legal grounds:

  • You have provided your explicit consent.
  • We need to process your special category or criminal convictions and offences personal data to establish, exercise or defend our legal rights such as when we are faced with any legal claims or where we want to pursue any legal claims ourselves.
  • We need to process your special category or criminal convictions and offences personal data for reasons of substantial public interest such as preventing or detecting unlawful acts such as fraud.

We have listed below the different ways in which we use your personal data and you will find details of the legal grounds we could rely on for each use. We only need to rely on one legal ground for each use of your personal data.

  1. To make credit-related decisions about whether and how much to lend to you. Following your application, we will search records held by credit reference agencies and we will use this information together with our own records to assess lending risks, such as your ability to pay back the loan, and set credit limits.

    Legal grounds:

    • Processing is necessary for the provision and administration of your consumer credit agreement
    • We have a legal or regulatory obligation to comply with
    • We have a legitimate business need

    Additional legal ground for special categories of personal data or personal data relating to criminal convictions and offences:

    • You have provided your explicit consent
  2. In circumstances where we are unable to accept your loan application, to make decisions about whether it would be appropriate to refer you to another credit broker or lender and transfer your personal data to third party credit brokers or lenders.

    Legal grounds:

    • We have a legitimate business need
    • You have provided your consent
  3. To verify your identity and the information you have provided to us, including by undertaking searches at credit refence agencies and fraud prevention agencies

    Legal grounds:

    • Processing is necessary for the provision and administration of your consumer credit agreement
    • We have a legal or regulatory obligation to comply with
    • Processing is necessary for reasons of public interest
    • We have a legitimate business need
  4. For administration

    Where you have opened an account with us we will use your personal data to:

    • set you up as a customer
    • update your records

    Where your loan application has been approved we will use your personal data to:

    • administer your loan including operating and managing your loan account
    • arrange for monies to be sent to you
    • take payments on loans
    • discuss repayments and make amendments to your loan plan if you are struggling with repayments
    • send correspondence to you about various matters, including your loan, any complaint that you might have, or with respect to any redress programme that might concern you
    • fulfil any other necessary purpose related to providing you with a loan
    • inform the Credit Reference Agencies about your loan repayments (or non-payments)

    Legal grounds:

    • Processing is necessary for the provision and administration of your consumer credit agreement
    • We have legal and regulatory obligations to comply with
    • We have a legitimate business need

    Additional legal ground for special categories of personal data or personal data relating to criminal convictions and offences:

    • You have provided your explicit consent
  5. To manage our business operations and infrastructure including maintaining accounting records, analysis of financial results, compliance with internal audit requirements, satisfaction of our own management information purposes and receipt of professional advice such as legal advice

    Legal grounds:

    • We have legal and regulatory obligations to comply with
    • We have a legitimate business need
  6. To develop and improve our products and our website, including our online account opening and application process and your online customer account (My account). To identify products that may be of interest to you and to market our products and services by email, SMS, letter or telephone

    Legal grounds:

    • You have provided your consent
    • We have a legitimate business need
  7. To detect and prevent criminal activity by investigating and prosecuting fraud, money laundering, terrorism and other crimes including by undertaking checks with fraud prevention agencies. To maintain records of cards that have been used fraudulently and report fraud to the Fraud Prevention Agencies

    Legal grounds:

    • Processing is necessary for the provision and administration of your consumer credit agreement
    • We have legal and regulatory obligations to comply with
    • Processing is necessary for reasons of public interest
    • We have a legitimate business need

    Additional legal ground for special categories of personal data or personal data relating to criminal convictions and offences:

    • You have provided your explicit consent
    • Processing is necessary for reasons of substantial public interest
  8. To carry out market research, surveys and business and statistical analysis, including the appointment of third parties to carry out such tasks on our behalf

    Legal grounds:

    • We have a legitimate business need

    Additional legal ground for special categories of personal data or personal data relating to criminal convictions and offences:

    • You have provided your explicit consent
  9. To perform administrative and operational tasks including the testing of the effective operation of our systems and its security

    Legal grounds:

    • We have legal and regulatory obligations to comply with
    • We have a legitimate business need
  10. To trace your whereabouts and recover any debt you owe us, including by undertaking searches at credit refence agencies and fraud prevention agencies

    Legal grounds:

    • We have a legitimate business need
  11. To improve quality, training and security with respect to our services (for example monitoring and recording telephone calls)

    Legal grounds:

    • We have a legitimate business need

    Additional legal ground for special categories of personal data or personal data relating to criminal convictions and offences:

    • You have provided your explicit consent
  12. To comply with our legal and regulatory obligations, including transferring personal data to independent external bodies such as governmental departments and agencies and our regulators (for example the ICO, FCA, CMA or FOS)

    Legal grounds:

    • We have legal and regulatory obligations to comply with
    • We have a legitimate business need

    Additional legal ground for special categories of personal data or personal data relating to criminal convictions and offences:

    • You have provided your explicit consent

6. Who do we share your personal data with?

We will share your personal data with Wonga employees, some of whom are based in the Republic of South Africa. We may also share your personal data with other companies in the Wonga Group (in administration) for general business administration purposes or, where you have provided your consent, for the provision of products and services offered by the Wonga Group (in administration), further details of which can be found in section 8 of this Privacy Policy. We may also disclose your personal data to the third parties listed below.

If you have a question about disclosure of your personal data, please see section 15 of this Privacy Policy for our contact details. We will share your personal data with the categories of third parties listed below either for the purposes explained in section 5 of this Privacy Policy or where you have provided your consent. Where appropriate, we take the required steps to ensure that your personal data is protected by placing the party we are transferring information to under contractual obligations to protect it and to use it only as permitted by us.

We may disclose your information to the following third parties:

  • Credit Reference Agencies (CRAs) and Fraud Prevention Agencies (FPAs), the ways in which CRAs and FPAs use and share your personal data are explained in more detail in section 7 of this Privacy Policy
  • Any firm, organisation or person we use to help us operate our lending business or to provide a service on our behalf, including providers of our payment systems, debt collection agencies we use to collect payments and recover debts, tracing agents or investigators, and suppliers who monitor use of social media to help us improve our credit decisions
  • Any firm, organisation or person who provides us with products or services or who we provide products and services to, including IT suppliers, auditors, marketing agencies, document management providers, tax advisers, post management and print providers, and suppliers who monitor the use of our website and online account opening and application process to help us improve the user experience
  • Any person who we reasonably believe to be your parent, carer or helper in circumstances where you are unable to handle your own affairs because of mental capacity or other similar issues
  • Banks or similar financial institutions
  • Law enforcement agencies to investigate and prevent crime
  • Law firms or any other organisations we instruct to provide legal advice or assist with legal proceedings
  • Debt Purchasers or other third parties to whom we sell your debt
  • Survey providers and third parties we appoint to carry out market research or business analysis
  • Selected third parties regarding the sale, transfer or disposal of our business
  • Our regulators (for example the ICO, FCA or CMA) and governmental authorities, ombudsmen (for example the FOS), or other authorities, including tax authorities
  • Other credit brokers or lenders to help them make decisions about whether to lend to you

We may also disclose your personal data to other third parties where:

  • you have provided your consent to the third party, for example insolvency practitioners, debt management companies and claims management companies; or
  • the disclosure is required by law or by a regulator with authority over us or you, for example where there is a statutory obligation or court order.

7. Credit Reference Agencies (CRAs) and Fraud Prevention Agencies (FPAs)

To process your loan application, we will perform credit and identity checks on you with one or more credit reference agencies (CRAs) and we will make periodic searches at CRAs to manage your account with us.

To do this, we will supply your personal data to CRAs and they will give us information about you. The data we supply will include information from your loan application and about your financial situation and financial history. CRAs will supply to us both public information (including from the electoral register and details of any county court judgments or bankruptcies) and shared credit, financial situation and financial history information (including information about previous credit applications and the conduct of your previous loan accounts) and fraud prevention information.

We will use this information to:

  • assess your creditworthiness and whether you can afford to take the product
  • verify the accuracy of the data you have provided to us
  • prevent criminal activity, fraud and money laundering
  • manage your account and your loans
  • trace and recover debts
  • ensure any offers provided to you are appropriate to your circumstances

We will continue to exchange 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.

If you fall behind with your payments and a full payment or satisfactory proposal is not received within 28 days of a formal demand being issued, a default notice may be recorded with the CRAs. Any records shared with CRAs will remain on file for 6 years after your account is closed, whether any outstanding sums have been settled by you or following a default.

When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders. Large numbers of applications within a short time period may affect your ability to obtain credit, this is applicable whether you have been accepted or declined.

If you have a spouse or financial associate, CRAs link your records together and these links will remain on your files until you or your partner successfully file for a disassociation with the CRAs to break that link.

If you give us false or inaccurate information and we have reasonable grounds to suspect fraud or we identify fraud we may record this and may also pass this information to fraud prevention agencies (FPAs) and other organisations involved in crime and fraud prevention, including law enforcement agencies who may access this information. If we determine that you pose a fraud or money laundering risk, we may refuse to provide you with a loan. A record of any fraud or money laundering risk will be retained by the FPAs and may result in others refusing to provide services to you. The FPAs can hold your personal data for up to 6 years.

The CRAs that we use are Callcredit Limited and Equifax Limited. Further details about these 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 www.callcredit.co.uk/crain and www.equifax.co.uk/crain.

The FPA that we use is Cifas, with registered office at 6th Floor Lynton House, 7-12 Tavistock Square, London, WC1H 9LT. You can contact Cifas at www.cifas.org.uk.

If you have any further questions about our use of CRAs or FPAs please contact us using the details set out in section 15 of this Privacy Policy.

8. What marketing activities do we carry out?

We may share information within the Wonga Group (in administration) to inform you of other products and services that might be of interest to you, but we will only do this where you have provided your consent.

We are committed to only sending you marketing communications that you would like to receive. If you wish to unsubscribe from emails sent by us, you may do so at any time by clicking on the 'unsubscribe' link that appears in all emails. Otherwise you can update your preferences in the 'My account' section of your online account or by contacting us using the details set out in section 15 of this Privacy Policy.

However, please note, if you opt out of receiving marketing emails we will continue to send you service related (non-marketing) communications, such as payment reminders.

9. How long do we keep your personal data?

We will only keep your personal data for as long as reasonably necessary to fulfil the relevant purposes set out in this Privacy Policy and in compliance with our legal and regulatory obligations.

Generally, your personal data will be held for the following time periods:

  • If you have taken out a loan - 7 years from the closure of your last loan i.e. from when the loan was paid in full or written off
  • If your loan is subject to any complaint, legal claim, redress or remediation - 6 years from the closure of the case
  • If you have had a loan application declined - 5 years from the decline decision
  • If you opened an account but did not apply for a loan - 90 days. However, if you opted in to receive marketing, we will hold your contact details (name, address, email address and telephone number) for 3 years.

If you have a question about the periods for which your personal data will be stored, please contact us using the details set out in section 15 of this Privacy Policy.

10. Security

We recognise how important it is to protect and manage the information you share with us and we are committed to keeping your personal data secure. We use a range of organisational and technical security measures to protect your information including safeguards such as firewalls and data encryption. We enforce appropriate physical access controls to our buildings, and we only authorise access to our buildings and files to those employees who require it to fulfil their job responsibilities.

When you share personal data with us through our website, that information is protected and our security systems meet or exceed industry standards.

11. Transfer of personal data

Our main database is kept in the UK. However, we also have operations in the Republic of South Africa and your personal data will also be accessed from that location. In addition, we (or third parties acting on our behalf) may process your personal data in countries outside the European Economic Area (EEA). In both cases when we transfer your personal data outside of the EEA we take the required steps to ensure that your personal data is protected by placing the party we are transferring information to under contractual obligations to protect it to adequate standards and, where relevant, by ensuring that such party is a member of a scheme that has been approved by the European authorities as providing a suitable level of protection, for example the Privacy Shield scheme agreed between the European and US authorities. If you have a question about the steps we take to safeguard your personal data, please contact us using the details set out in section 15 of this Privacy Policy.

12. Your rights

Under data protection law you have certain rights in relation to the personal data that we hold about you. You may exercise these rights at any time by contacting us using the details set out in section 15 of this Privacy Policy.

Please note that in some cases we may not be able to comply with your request for reasons such as our own obligations to comply with other legal or regulatory requirements. However, we will always respond to any request you make and if we can't comply with your request, we will tell you why. Your rights include:

The right to access your personal data

You are entitled to a copy of the personal data we hold about you and certain details of how we use it. This is called a Data Subject Access Request, which you can make by writing to [email protected]. There will not usually be a charge for dealing with these requests.

Your information will be provided to you in writing, unless otherwise requested.

You also have the right to request the credit reference agencies and fraud prevention agencies to provide you with the information that they hold about you. You must contact them directly to do this.

The right to rectification

We want to make sure that your information is accurate and up to date. You may ask us to correct or remove any information that you think is inaccurate or you can update your contact details, personal details and payment details yourself in the 'My account' section of your online account.

The right to erasure

You have the right to ask us to erase your personal data, for example where you withdraw your consent to our processing (if we are relying on consent as our legal ground). However, we usually retain personal data in accordance with applicable laws (for example, laws that specify how we manage your credit agreement) which may mean we cannot process your request.

The right to restriction of processing

In certain circumstances, you are entitled to ask us to stop using your personal data, for example where you think the personal data we hold about you may be inaccurate.

The right to data portability

In certain circumstances, you have the right to ask that we transfer personal data you have already provided to us back to you or to a third party.

The right to object to the processing of your personal data (for example, marketing emails)

Where we process your personal data on the legal ground that we have a legitimate business need, you may object and we will consider your objection. Please use the contact details set out in section 15 of this Privacy Policy.

You can ask us to stop sending you marketing messages at any time. You can do this either by clicking the 'unsubscribe' link that appears in all emails, or you can update your preferences in the 'My account' section of your online account, or you can contact us using the details set out in section 15 of this Privacy Policy.

The right to request a manual review of an automated decision (including profiling)

Credit-related decisions about whether and how much to lend to you are made automatically. We process the personal data you have provided to us, together with any of your personal data included in our records such as previous loan payment history and that which we have obtained from the credit reference agencies and fraud prevention agencies. We use this information to evaluate automatically your ability to pay back a loan and provide you with a credit score, which enables us to make fair and responsible lending decisions. The consequence of this automated processing is that we may decide not to lend to you or we may decide to offer to lend to you an amount less than you applied for. The credit scoring methods we use to make these credit-related decisions are regularly tested to ensure they remain fair, effective and unbiased.

We also decide automatically whether you pose a fraud or money laundering risk. We process your information to see if your behaviour is either consistent with that of known fraudsters or money launderers or inconsistent with your previous submissions, or you appear to have deliberately hidden your true identity. The consequence of this automated processing is that we may decide not to lend to you and we may pass this information to fraud prevention agencies and other organisations involved in crime and fraud prevention.

You may contact us to request that any decision to decline your loan application is reconsidered manually by our employees using the contact details set out in section 15 of this Privacy Policy.

The right to withdraw consent

For certain uses of your personal data, we will ask for your consent. Where we do this, you have the right to withdraw your consent to further use of your personal data (if we are relying on consent as our legal ground).

The right to lodge a complaint with the ICO

You have a right to complain to the Information Commissioner's Office (ICO) if you believe that any use of your personal data by us is in breach of applicable data protection laws and regulations.

More information can be found on the ICO's website: ico.org.uk.

Making a complaint will not affect any other legal rights or remedies that you have.

13. Third party links

Our website may contain links to third party websites. If you follow a link to any of these websites, please note that these websites have their own terms and conditions and privacy policies and we do not accept any responsibility or liability for their policies or processing of your personal data. Please check these policies before you submit any personal data to such third-party websites.

14. Social Media Features

Our website includes Social Media Features such as the Facebook Like button. These Features may collect your IP address, which pages you are visiting on our site and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted on our site. Your interactions with these Social Media Features are governed by the privacy policy of the company providing it.

You can find more information about this in our Cookies Policy.

15. Contact Us

If you have any questions about how we collect, store or use your personal data, you may contact us by email at [email protected], by phone 020 7138 8330 or by letter for the attention of the Data Protection Officer, WDFC UK Limited (in administration), The Harlequin Building, 65 Southwark Street, London, SE1 0HR

16. Updates to this Privacy Policy

We may update this Privacy Policy from time to time to ensure that it remains accurate. Please check the latest version each time that you provide additional personal data to us.

This Privacy Policy was last updated on: 21st May 2018.