Privacy notice

Introduction

Perfect Data Solutions Limited t/a LendingMetrics (“LendingMetrics”) respects your privacy and is committed to protecting your personal data. This privacy notice is our way of providing you with information, such as explaining why different types of personal data are collected and used, how that data is used and disclosed and an individual’s rights regarding their data.

1. Important Information and Who We Are

This Privacy Notice aims to give you information on how LendingMetrics collects and processes your personal data through your use of this website, including any data you may provide through this website, book a demo or contact us.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and privacy policies and is not intended to override them.

Controller

LendingMetrics is both a data processor and a data controller (depending on the product and services offered) and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy notice).

We have appointed a data protection officer (DPO), Neil Williams, who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact Details

If you have any questions about this privacy notice or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: Perfect Data Solutions Limited t/a LendingMetrics Email address: DPO@lendingmetrics.com

Postal address: 1650 Parkway, Whiteley, Fareham, Hampshire PO15 7AH

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Privacy Notice and your duty to inform us for changes

We may change this notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be made available through our website and will be deemed to be accepted by you upon your first visit following the publication of any update. You are reminded to check the relevant page of our website for updates.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows (this may vary according to your relationship with us):

Identity Data includes first name, maiden name, last name, username or similar identifier, NI number, employment information, date of birth.
Contact Data includes postal address, email address and telephone
Financial Data includes bank
Transaction Data includes details about payments to and from you, credit agreements, credit payment history.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by
Usage Data includes information about how you use our website (such as what you click, what you view, how long you spend on the ages).
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. Please note that you will always have the opportunity to opt-out.
Aggregated Data includes statistical or demographic data. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data 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). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

Direct interactions

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

Apply for our products or services
Subscribe to our service or publications
Request marketing to be sent to you
Give us feedback or contact

Automated technologies or interactions

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see below for further details.

Third parties or publicly available sources.

We may also receive and/or collect personal information about you from various third parties and public sources such as business directories, public registers and other commercially or publicly available sources.

Technical Data

Technical data may be collected from the following parties:

Analytics providers (such as Google, based outside the UK)
Search information providers (such as credit reference agencies, Companies House, Electrical Register)

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances (lawful basis):

Where it is necessary for our Legitimate Interests (or those of a third party) and your interests and fundamental rights do not override those interest
Where it is necessary for the Performance of Contract that we are about to enter into or have entered into with you
Where we need to comply with a legal

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us.

Whilst we do not make any automated decisions based upon your Personal Data, some of our clients may utilise a software platform we provide called “Auto Decision Platform” (ADP) to make automated lending decisions in respect of credit applications received from consumers/applicants.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy notice (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

LendingMetrics Products (where LendingMetrics act as Data Controller)

LMX

We procure searches from the main credit reference agencies. We use this data to provide credit search services to our clients. Our clients are predominantly lenders who use our data in order to make lending decisions to consumers by obtaining, amongst other things, credit reference reports, anti-money laundering checks, fraud detection reports and identity verification reports from us; we call this service LMX.

OpenBankVision

We provide software platforms for our clients to make lending decisions. This can involve data capture of a consumer’s recent bank account activity. These services are called Bank Vision and OpenBankVision.

Marketing – Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please refer to our Cookies Policy.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosure of Your Personal Data

Personal data is shared to our clients as part of the commercial services we provide.

Our clients must demonstrate a legitimate business reason for using our services and enter into agreement with us to ensure that they will protect the integrity and confidentiality of any personal data they receive from us and maintain adequate security in order that any breach of data is minimised.

Generally, a consumer will be notified of credit searches being undertaken on their behalf.

Our clients are also required to inform of us of any material change to any personal data within a reasonable time.

Any inaccuracies in personal data should be reported to us. As we rely upon receiving reports of personal data and upon public registers, we cannot be held responsible for the accuracy of your Personal Data. We shall investigate any inaccuracies notified to us and if these cannot be resolved we shall notify you in order that you can seek to resolve with the reporting entity directly.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, to help prevent fraud, tax evasion or money laundering or upon the instructions of a government authority.

6. International Transfers

We do not transfer your personal data outside of the UK.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. Different retention periods apply for different types of personal information and services offered, for example:

Personal Data where LendingMetrics is the Data Controller:

LMX	LMX Searches sourced from a credit reference agency will be securely retained for up to 12 months before being purged. Monthly Reporting files are supplied from the Client and passed to the relevant credit reference agency. LendingMetrics will securely retain each monthly reporting file for up to 3 months before being purged.
OpenBankVision	Searches that do not result in Bank Statement data will be securely retained for up to 3 months before being purged. Searches that do result in Bank Statement data will be securely retained for up to 12 months before being purged.
Employee/Prospective Employee	LendingMetrics will collect data through CV’s and applications during any interview process. Any applications that are unsuccessful will be retained by the company for a 12-month period. All employee data will be retained for the entirety of their employment. After employment the company will retain elements of the data in order for the company to conduct references for new employers, this data will be kept for up to 7 years.
Client/Prospective Client	LendingMetrics will keep the data for the entirety of the contract. Upon expiry of the contractual relationship, LendingMetrics will hold the data for up to 7 years (this is to ensure that we are able to inform historical clients of any changes that may be of interest to them or their business needs).

Personal Data where LendingMetrics is the Data Processor on behalf of our Client (the Data Controller)

ADP

Submitted transactions will be securely retained based on the Clients’ own stated Data Retention Policy, typically between 3 - 12 months. The Client should be contacted directly for clarification.

LMX

From time to time a Client may provide a batch file containing bulk Consumer

data used to run a retrospective analysis. In this process LendingMetrics acts as a Data Processor, therefore will securely retain each file for up to 6 months before being purged.

DeeJoop

Submitted transactions will be securely retained typically for a period of 30 days before being purged

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. Generally, we will not hold your personal information for more than 6 years.

When it is no longer necessary to retain your personal information, we will delete or anonymise it.

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. In summary, these rights include:

Be Informed: right to be informed over how we use your use personal
Access: right to access to your personal information and to certain other supplementary information. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it (commonly known as a "data subject access request"). A Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
Rectification: right to request the correction of the personal data that we hold about you. 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.
Erasure: right to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local 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.
Restrict processing: right to request restriction or suppression of processing your personal data in the following scenarios:
- If you want us to establish the data's
- Where our use of the data is unlawful but you do not want us to erase
- 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.
Data Portability: the right to move, copy or transfer your personal data to you or to a third We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Object: right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms and an absolute right to stop your data being used for direct marketing. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Automated decision making (including profiling): right to object to decisions being taken by automated means including profiling which produce legal effects concerning you or similarly significantly affect you or to our continued processing of your personal information.
Withdraw consent: right to withdraw your consent at any time where we are relying on consent to process your personal However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us using the details above.

No Fee is usually required

You will not have to pay a fee to access your personal data (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.

What We May Need from You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. General

This Privacy Notice was last updated 25 July 2024.

You may not transfer any of your rights under this notice to any other person. We may transfer our rights under this notice where we reasonably believe your rights will not be affected.

If any court or competent authority finds that any provision of this notice (or part of any provision) is invalid, illegal or unenforceable, that provision or part provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this notice will not be affected.

Unless and otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

11. Governing Law and Jurisdiction

These terms and any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with it or its subject matter or formation shall be governing by and construed in accordance with the laws of England and Wales.

Each party irrevocable agrees that the courts of England and Wales shall have non-exclusive jurisdiction to settle any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with these terms or its subject matter or formation.

12. Glossary

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.