Mutual Clothing & Supply Company Limited (“Mutual”) Privacy Notice
ABOUT US
Mutual Clothing & Supply Company Limited ("We") are committed to protecting and respecting your privacy. For the purposes of the relevant data protection legislation, the “data controller” is Mutual Clothing & Supply Company Limited of 39 Bedford Street South, Leicester, LE1 3JN. We are authorised and regulated by the Financial Conduct Authority. Our ICO data protection registration number is Z5567862.
This Notice sets out the basis on which we collect personal data (as defined below) from you and the way in which it will be processed by us. Please read this Notice carefully to understand our views and practices regarding your personal data and how we shall treat it.
It is important that you read this Notice together with any other privacy notice or fair processing notice that 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 personal data. This Notice supplements any other such notices and is not intended to override them.
If you have any questions about this Notice, including if you wish to send us a request to exercise any of your legal rights, please contact us at [email protected] or 0116 251 8106 or visit a local Mutual branch.
WHY DO WE COLLECT INFORMATION
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:
1. To provide our products or services to you, either at your request or in order to fulfil an existing contract;
2. Where we need to comply with a legal or regulatory obligation; or
3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
“Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service or product and the secure experience. We ensure that we consider and balance any potential impact on you 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).
TYPES OF PERSONAL DATA WE COLLECT
“Personal data” means any information which identifies (or from which we can identify) a natural person. We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:-
• “Identity Data”, which comprises your first name, maiden name, last name, marital status, title, date of birth, gender and next of kin details.
• “Lifestyle Data”, which comprises of details relating to your household expenditure, your number of dependents, residency type and tenure, and any other information relating to your family, lifestyle or social circumstances if relevant to the product or service in question.
• “Employment Data”, which comprises of your occupation, employment status, details of your employer and length of employment.
• “Contact Data”, which comprises your address, any previous addresses, email address and telephone number(s).
• “Financial Data”, which comprises your income and salary details, (including details of any benefits), any other types of income, details of other credit commitments, bank account and payment card details.
• “Transaction Data”, which comprises details about credit payments we have made to you, and repayments we have received from you.
• “Technical Data”, which comprises your IP address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the device(s) you use to access http://www.mutual.uk.com (“our Website”) or the Mutual App (“our App”)
• “Profile Data”, which comprises details of products or services you have requested from us, details relating to live or settled customer credit accounts and applications, past credit applications (whether successful or unsuccessful), your interests, preferences, feedback and survey responses and your username and password for your customer account on our Website, but excluding Special Categories of personal data, as defined below.
• “Usage Data”, which comprises information about how you use our Website, App, products and services.
• “Marketing and Communications Data”, which comprises your preferences in receiving marketing from us and third parties, and your communication preferences.
Joint Applications
If you are making a joint application, you must have the joint applicant’s authority to provide their personal data to us as part of the application. You will need to share with them details of what you have disclosed about them to us on their behalf. You must ensure that they have read and understood this Notice and have agreed the information to be shared before it is provided to us as part of a joint application.
Aggregated Data
We also collect, use and share “Aggregated Data” such as statistical or demographic data. Aggregated Data may be derived from your information but does not constitute “personal data” in law as it does not directly or indirectly reveal your identity. For example, we may aggregate (i.e. combine with information relating to others) your Usage Data to calculate the percentage of users accessing a specific feature of our Website. However, if we combine or connect Aggregated Data with your information so that it can directly or indirectly identify you, we treat the combined data as personal data which will be handled in accordance with this Notice.
Special Categories of Personal Data
We may collect “Special Categories” of personal data about you which includes details about your health and any medical conditions that you, or a joint applicant may have. There is no obligation for you to provide us with this information but you may wish to provide it to us if you wish for us to take this information into account when we are considering your application for credit or when managing your credit account.
As you are under no obligation to provide this information to us and it is not strictly necessary for the purposes of the application, we will only process Special Categories of personal data about you with your explicit, opt in consent to do so for the purpose specified above.
We also do not collect any information about criminal convictions and offences. We do not knowingly collect and personal data about children.
Minimum Required Information
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 the minimum required 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 enter into a consumer credit agreement with you following a successful application for credit). In that event, we may have to cancel our agreement with you to provide a product or service you have ordered or requested, and will notify you if this is the case at the time.
WHEN DO WE COLLECT INFORMATION
We may collect information on you in the following ways:
• Information that you voluntarily provide to us.
When you complete our credit application form, create a customer account for our Website, consult with our customer service team, employed agents or staff, communicate with us by phone, email, post or otherwise, fill in forms on our Website, enter a competition, promotion or survey, or make transactions using, or otherwise make use of, our App, you are voluntarily giving us information that we collect. We also collect information you give to us when we contact you during the application process or in the process or managing your account. That information may include your Identity Data, Contact Data, Lifestyle Data, Employment Data, Financial Data, Transaction Data, Profile Data and Marketing and Communications Data.
• Information that we collect automatically.
When you browse our Website, we may collect information about your visit to our Website and your web browsing. That information may include your Technical Data and Usage Data. We may collect this information as a part of log files as well as through the use of cookies or other similar technologies. Our use of cookies and similar technologies is explained more fully in our Cookie Policy.
• Information from other sources.
From time to time we may obtain information about you from third party sources, such as public databases (for example the Electoral Register), credit reference agencies and other third party data providers. For more information about the information we obtain from credit reference agencies please see the Credit Reference Agencies section of this Notice www.mutual.uk.com/crain.
We take steps to ensure that such third parties are legally permitted or required to disclose such information to us. Examples of the information we may receive from other sources include: demographic information, device information (such as IP addresses), location, and online behavioural data (such as information about your use of social media websites, page view information and search results and links) from analytics providers and search engine providers. We use this information, alone or in combination with other information (including personal data) we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products features, and services.
• Information from Credit Reference Agencies and Fraud Prevention Agencies.
In order to process your application, we will perform credit and identity checks on you with one or more credit reference agencies (“CRAs”). Where you enter into a credit agreement with us we may also make periodic searches at CRAs to manage your account with us.
To do this, we will supply your personal information to CRAs and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information 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(s);
• Trace and recover debts; and
• 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. When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.
If you are making a joint application, or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. CRAs will also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.
The identities of the 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.mutual.uk.com/crain.
CRAIN is also accessible from each of the three CRAs – going to any of these three links will also take you to the same CRAIN document: TransUnion www.transunion.co.uk/crain ; Equifax www.equifax.co.uk/crain ; Experian www.experian.co.uk/crain/index.
HOW WE USE YOUR INFORMATION
We have set out below a description of all the ways we intend to use any personal data, and which of the legal bases we intend to rely on in order to do so. We have also identified what our legitimate interests are where appropriate. You can obtain further information about how we assess our legitimate interests against any potential impact on you in relation to specific activities by contacting us [email protected] or 0116 251 8106. We may use and disclose your personal data for the following purposes:-
a) Processing your credit application or order
In processing your application for credit or your order, we will use your Identity Data, Lifestyle Data, Contact Data, Financial Data, Employment Data, Transaction Data, Profile Data and Marketing and Communications Data and any data received from credit reference agencies. If you are making a joint application, we will also use the personal data provided by you relating to the joint applicant for this purpose. We will use this information to assess your creditworthiness and to determine whether you are eligible for the credit you have applied for, verify your identity and to take necessary steps to prevent fraud.
We will also use this information in order to carry out our obligations arising from any contracts entered into between you and us to provide you with our products and services. This includes processing applications for credit and entering into a consumer credit agreement with you if you are approved for credit, managing and processing your credit account or Website customer account, or entering into transactions through use of the App, despatching your orders as well as processing and collecting repayments. This information will also be used to enable us to keep adequate records of your past credit applications and purchases, which we will assess if you apply for further credit in the future. Your Contact Data will be used to contact you regarding your credit account, Website account or order and for warranty purposes or if you have requested for us to visit your home in order to discuss our services.
b) Information we receive from credit reference agencies
The information we receive about you from credit reference agencies will be used to assess your creditworthiness, to determine whether you are eligible for the credit you have applied for, verify the accuracy of the data you have provided to us and your identity, prevent criminal activity, fraud and money laundering, manage your credit account and to ensure that any offers provided to you (which you have provided your opt-in consent to receive) are appropriate to your circumstances. We will also use this information for our legitimate interests in order to help us trace and recover payment of any outstanding debts.
c) Credit Scoring
As part of the credit application process, we will use credit scoring to help us to assess your creditworthiness and to determine whether you are eligible for the credit you have applied for. Our credit scoring uses information from your credit application (including Identity Data, Contact Data, Financial Data, Employment Data, Transaction Data, Profile Data and Marketing and Communications Data), information we receive about you from credit reference agencies and information we already hold about you such as your previous repayment record. There is always a human involved in any decision to lend to you so your credit application will never be declined due to a solely automated decision making process.
d) To manage our relationship with you
We may use your Contact Data to send you important updates about changes to the way in which our products or services work.
We may also use the information you provide to us to allow certain payment arrangements or to continue or extend existing payment arrangements and assess any new applications for credit.
e) Marketing
When you take a service from us we will discuss with you your marketing preferences. If you have told us that you are happy to receive marketing information, we may send you, or permit selected third parties to send you, other forms of marketing, for example regarding our other products and services. We may continue to contact you in this manner after you have settled your credit account with us. You have the right to withdraw permission to receiving direct marketing at any time by contacting us or visiting your local Mutual branch.
f) Advertising
We may use the information that we collect in order to deliver relevant website content and advertisements to you and to measure or understand the effectiveness of the advertising we serve. We also use data analytics to improve our Website, products and services, marketing, customer relationships and experiences. This is in order for us to be able to study how customers use our products or services and develop them, to grow our business and to inform our marketing strategy. For more information on how we use cookies or other similar technologies for these purposes, as well as how to opt-out of the use of cookies, please visit our Cookie Policy.
g) To administer and protect our business and this website
We may also use your information in order to protect our business and our Website, and to help us monitor or improve the products or services that we offer. This includes troubleshooting, statistical and data analysis, testing, system maintenance, support, reporting and hosting of data. We also use your information to improve our Website so that content is presented in the most effective manner for you and for your computer, and as part of our efforts to keep our site safe and secure. This is necessary for the running of our business, provision of administration and IT services, network security and prevention of fraud. We may also need to use your information in the context of a business reorganisation or group restructuring exercise.
g) Other purposes
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 lawful reason and that reason is compatible with the original purpose. If you require an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us [email protected] or 0116 251 8106. 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 where this is required or permitted by law.
WHEN WILL WE SHARE YOUR PERSONAL DATA?
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. We shall not share your personal data with any third parties for marketing purposes without your express consent. We shall however, share your personal data with third parties, for the following reasons:-
(a) Service Providers.
We will share your personal data with service providers where this is necessary in order to provide you with products or services that you have ordered. Examples of Service Providers include payment processors, hosting services, suppliers, sub-contractors and delivery providers. We may also need to share your personal data with third party software or IT support providers for the purpose of system administration, data security, data storage, back up, disaster recovery and IT support.
(b) Credit reference agencies.
We will share details about your credit application, regardless of whether or not it is accepted, with credit reference agencies, including details of your customer credit accounts, how you manage them, whether you have missed any repayments and details of any settled credit accounts. For more information, please visit the WHEN DO WE COLLECT INFORMATION section of this Notice.
(c) Advertising partners.
We may partner with third party advertising networks and exchanges in order to display advertising on our Website or to manage and serve our advertising on other sites, and may share personal data with them for this purpose. All third parties with which we share this information are required to use your personal data in a manner that is consistent with this Notice. We and our third party partners may use cookies and other tracking technologies, such as pixels and web beacons, to gather information about your activities on our Website and other sites in order to provide you with targeted advertising based on your browsing activities and interests. For more information about cookies and other tracking technologies, please visit our Cookie Policy.
(d) To transfer your information in the case of a sale, merger, consolidation, liquidation, reorganisation, or acquisition.
We may share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Notice.
(e) To protect the rights, property, or safety of our business and other customers.
We reserve the right to disclose or share your personal data in order to comply with any legal or regulatory requirements, enforce our terms and conditions (or any other agreement we enter into with you), or to protect the rights, property, or safety of our business and other customers. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. We may also need to share information with HM Revenue & Customs, the Financial Conduct Authority, the Financial Ombudsman and other authorities acting as processors based in the United Kingdom, who require reporting of processing activities in certain circumstances and in order to ensure that we are complying with regulatory requirements.
We may also share your personal data with third parties to conduct satisfaction surveys in order to help grow and improve our business, the products and services we offer and to ensure that we are complying with our regulatory obligations.
We may also share your personal data with our professional advisers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services.
Third Party Websites
Our 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 that you visit.
International Transfers
We will not transfer your data outside the EEA.
ARE COOKIES USED?
Our Website uses cookies to distinguish you from other users of our Website and to enhance customer experience. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website. For detailed information on the cookies we use and the purposes for which we use them please visit our Cookie page.
WHERE WILL WE STORE YOUR PERSONAL DATA?
All electronic personal data that you provide to us is stored on our secure servers. Physical application forms and credit agreements are stored securely at the local Mutual branch in which they were completed. We use our best endeavours to ensure that your data is treated securely and in accordance with this Notice and comply with the relevant data protection legislation within the United Kingdom.
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. For example, our servers are kept in a secure, access controlled environment and physical application forms and credit agreements are stored in alarmed premises. 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.
Please note that the transmission of information via the internet is not completely secure. Although we shall 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 information, we shall use effective safeguarding procedures and security features to try to prevent any unauthorised access to your personal data.
HOW LONG WILL WE KEEP HOLD OF YOUR PERSONAL DATA
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request details of by contacting us.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Where you have given us your permission to contact you for marketing purposes, we shall discuss with you whether you wish to receive marketing content from us when you settle your accounts and your agent will contact you periodically to see if you still wish to hear from us. You can ask us to stop sending you marketing information at any time.
In some circumstances you can ask us to delete your data: see the “Right to be Forgotten” section below for further information.
Contacting you about our products and services
With your permission, we may contact you by email, phone, SMS text and by post to tell you about our products we feel you may be interested in. We may continue to contact you after you have settled your account. You can tell us to stop contacting you with marketing information at any time by phoning, writing or emailing us.
YOUR RIGHTS
Under certain circumstances, you have the following rights:
1. to request that we provide you with a copy of the personal data that we hold about you (“Access Request”);
2. to request that we rectify any personal data that we hold about you (“Right to Rectification”);
3. to request that we erase any personal data that we hold about you (“Right to be Forgotten”);
4. to restrict the level of processing we carry out with your personal data (“Restriction of Processing”);
5. to obtain from us all personal data that we hold about you in a structured, machine readable form, and have this information transmitted to another organisation (“Data Portability”);
6. to object to our processing your personal data in certain ways (“Right to Object”); and
7. to withdraw your consent at any time to our processing of your personal data.
Please see the relevant sections below for further details on your rights as a data subject. You can exercise any of the above rights by contacting us at [email protected] or 0116 251 8106. You also have the right to lodge a complaint with the Information Commissioner’s Office if you are unhappy in any way with how we have treated your personal data. We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner’s Office, so please contact us in the first instance. If you wish to lodge a complaint at the Information Commissioner’s Office you can do so:
• by telephone on 0303 123 1113
• in writing at: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
• by visiting their website http://www.ico.org.uk
We shall comply with any request made under this section as soon as possible, and normally within one month from the date of your request. However, if necessary, for example if your request is particularly complex or we receive a number of similar requests, we may extend this period by an additional two months, but we shall notify you if we need to do this.
You will not usually have to pay a fee to access your personal data (or to exercise any of your other rights). However, please note that where we receive requests under this section which are manifestly unfounded or excessive, for example because they are repetitive in nature, we may:
1. charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested; or
2. refuse to act on the request.
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.
ACCESS REQUEST
You have the right to request a copy of the information that we hold about you at any time. This enables you to receive a copy of the personal data that we hold about you and to check that we are lawfully processing it. Please note that in most circumstances, we shall not make a charge for this. However, we may charge a reasonable fee based on administrative costs for any further copies requested.
RIGHT TO RECTIFICATION
You have the right at any time to ask us to rectify any personal data that we hold for you which is incorrect or incomplete. This enables you to have corrected any incomplete or inaccurate data we hold about you, though we may need to verify the accuracy of the new data that you provide to us.
If we have disclosed any incorrect or incomplete data to any third parties, we shall inform them of any necessary amendments or corrections made to your personal data under this section.
RIGHT TO BE FORGOTTEN
You have the right to ask us to erase the personal data that we hold about you in circumstances where:
1. it is no longer necessary for us to handle your personal data for the purpose for which it was originally collected;
2. you have withdrawn your permission for us to hold your personal data (where this was the basis on which it was collected or used);
3. you object to the processing of the data and there is no lawful overriding reason for us to continue processing your personal data;
4. the personal data was unlawfully processed; or
5. we have to erase your personal data in order to comply with a legal obligation.
Please 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.
RESTRICTION OF PROCESSING
You can ask us to restrict how we use your data in the following circumstances:
1. where you believe that the information we hold about you is inaccurate, you can ask that we refrain from using your data until we can verify the accuracy of it;
2. where we have unlawfully processed your data, you can ask that we restrict our usage of it rather than erase it completely;
3. where we no longer need to hold your information, but you wish us to retain your information for the purpose of establishing, exercising or defending a legal claim; or
4. where you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
DATA PORTABILITY
You have the right to obtain from us all personal data which you have provided to us in a structured, commonly used and machine readable form, provided that such data was processed based on your consent, or for the purpose of a contract between us and the processing was carried out by automated means. Please 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.
This will allow you to move, copy or transfer personal data easily from one IT environment to another. Alternatively, we can transmit such data directly to another organisation.
Please note that we shall not be able to comply with a data portability request if this will affect the rights and freedoms of others.
RIGHT TO OBJECT
You have the right to object, on grounds relating to your particular situation, to our processing of your personal data where we are doing this for the performance of a task carried out in the public interest (which we shall have told you about, if applicable), or where we are carrying out processing for the purposes of legitimate interests pursued by us.
You also have the right at any time to ask us not to process your personal data for direct marketing or profiling purposes (to the extent that such profiling is related to such direct marketing). We shall have informed you before the time we obtained your personal data whether we intend to process your personal data for this purpose, or if we intend to disclose your information to any third party for such purposes.
If we process your personal data for automatic decision making or profiling purposes (i.e. to analyse or predict your personal preferences and purchase behaviour, and such profiling is automated) we shall tell you about this beforehand, and will only do this where this is a necessary condition of entering into a contract between you and us, or where you have given us your explicit consent to do this.
RIGHT TO WITHDRAW CONSENT
Where you have given us your consent to our processing of any of your personal data, you have the right to withdraw your consent at any time, for example if you no longer wish us to share your information with third parties for marketing purposes (where you have previously consented to this). 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.
In addition to any other way we make available to you the ability to withdraw your consent, you may also withdraw your consent at any time by contacting us at [email protected] or 0116 251 8106 or by visiting a local Mutual branch.