Privacy Policy

APFIN LTD trading as Polar Credit ("We") are committed to protecting and respecting your privacy.

This policy (together with our Terms of use) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Our Privacy Policy applies both while you have a credit agreement from us and afterwards.

For the purpose of the Data Protection Act 1998 (the "Act"), the data controller is APFIN LTD with a registered office at 3rd Floor, 12 Gough Square, London, EC4A 3DW. We are registered with the UK Information Commissioner under the Act and our registration number is Z3194688.

Information we may collect from you

In order to assess your application for a Polar Credit Line, we need to collect some of your personal information. We may collect and process the following data about you:

Information that you provide by filling in forms on our site polarcredit.co.uk ("our site"). This includes information provided at the time of making an application for credit or requesting further services. We may also ask you for information when you report a problem with our site.
Information that you provide to us when accessing your account.
Information which you provide when we contact you, or when you contact us, via the website, by email, phone, text or post. We may keep a record of that correspondence, including monitoring and / or recording telephone calls.
Your answers to surveys we may ask you to complete that we use for research purposes, although you do not have to respond to them.
Details of transactions you carry out through our site and of the fulfilment of your instructions, including details of any transactions with third parties which you complete through using our site.
Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

We may also collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.

We use Secure Socket Layer (SSL) technology to protect the data that we collect from you. SSL is an industry standard encryption technology used by companies to secure their online transactions with their customers. You can verify our use of SSL technology for protecting your data by the HTTPS letters in the address bar of your web browser.

Our lawful bases for processing your personal data

Contract
- In order to fulfil our contractual obligations to you, or because you have asked us to do something before entering into a contract
Legal Obligations
- In order to comply with legal and statutory obligations, such as FCA and ICO regulations
Legitimate Interests
- In order to pursue our reasonable commercial interests
Consent
- To offer you any services provided by APFin Limited, or other companies, that we think may genuinely interest you, subject to you providing your consent.

Purpose for processing your data

We use your data in the following ways:

To assess and process your application for credit, and to make a lending decision about you;
To carry out our obligations arising from any contracts entered into between you and us;
To collect your repayment(s) directly, or if you don’t engage with us, via transfer to a debt collector;
To comply with statutory obligations, such as record keeping in relation to FCA regulations and HMRC;
Where appropriate, to cooperate with agreements that you may make with third parties which concern your contractual obligations to us or a complaint against us, such as debt management companies, insolvency practitioners and claims management companies, where you have consented to us discussing the agreement with the third party or it is our legal obligation to do so;
To notify you about changes to our service;
To provide you with information, products or services from brands of APFin Limited and other related services, including but not limited to, price comparison websites, that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
To ensure that content from our site is presented in the most effective manner for you and for your computer;
To allow you to participate in interactive features of our service, when you choose to do so;
To allow you to review our service via certain review sites such as TrustPilot, via an emailed link.

For the purposes of fulfilling your application to borrow money from us, we may pass your data to:

credit reference agencies;
other companies or organisations which need your data to fulfil your credit application (for example your bank).

If your loan application with us is unsuccessful, and you consent to us doing so, we may pass your application details to:

• Leadtree Global Limited (FCA reference number 728649), Stop Go Networks Limited (FCA reference number 729572) or T.UK (FCA reference number 688026), so that they may help you find an alternative lending solution by providing your details to other lenders on their panel. These lenders may carry out additional credit searches in order to assess whether they are able to offer you credit and you may be contacted by Leadtree Global, Stop Go Networks, T.UK or any lender that has approved your application for the purpose of progressing your application with them.

Our partners have their own privacy policies. To view Leadtree Global's click here. To view Stop Go Networks' click here. To view T.UK's click here.

The panel that can consider your application if your application with us is unsuccessful includes: Stagemount Limited, Quidie limited, Valour Finance Limited, Tiger Lion Financial Limited, SERPABLE LTD, Fizzyy LTD, Mindflow Marketing Ltd, Loan Machine Limited, GC DataTech Ltd, My Finance Club Limited, MediaBlanket Ltd, Cockle Finance, GAIN Credit LLC, Shelby Finance Ltd, Choose Wisely Limited, Everything Financial Technologies Limited, Gracombex Ltd, ESL Consultancy, Monevo Limited, Salad Finance Limited, PDL Finance Limited, Loans 2 Go Limited, Fund Ourselves Ltd, Creditstar UK Limited, PingYo Inc, UK Credit Limited, The One Stop Money Shop Ltd, STS Commercial, ScoresMatter Limited, Evergreen Finance London Limited, Loqbox Technology UK Limited, Inclusive Finance Ltd, Western Circle Ltd, The One Stop Money Shop Ltd, Savvy Loan Products Ltd, Everyday Lending Ltd, TM Advances Ltd, Norwich Trust Limited.

When third parties use your data to provide you with products or services, they will be acting as data controllers of your information. If you enter into a contract with a third party through our site, the information you provided to us together with any further information requested by, and supplied by you or us to the third party will be held and used by the third party in accordance with their privacy policy. Therefore, you are strongly advised to read your chosen provider's privacy policy and satisfy yourself as to the purposes for which the provider will use your personal information before entering into the contract. We have no responsibility for the uses to which a provider puts your personal information.

We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in London). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.

Credit checks and automated credit scoring

When assessing your application for credit, to prevent fraud, to check your identity and to prevent money laundering we may search the files of fraud prevention agencies and credit reference agencies who will record any credit searches on your file (whether or not your application is successful). If your application is successful, we will also disclose the details of your credit agreement(s) and how you conduct your account to such agencies. We will notify credit reference agencies and fraud prevention agencies if any of the information you have provided us is false or inaccurate. The information will be used by other finance companies and credit brokers for making credit decisions about you and the people with whom you are financially associated, for fraud prevention, money laundering prevention and occasionally for tracing debtors. Information used for these purposes will include publicly available information such as electoral roll, county court judgments, bankruptcy orders or repossessions and fraud prevention information.

Where information held about you by a credit reference agency is linked to records relating to another person (an "association") you may be treated as financially associated with that person and records relating to each of you may be searched and taken into account in relation to any application made by either of you until one of you successfully files a disassociation at the credit reference agencies.

If you have told us that you are financially associated with another person, you are declaring that you are authorised to:

disclose information to us about that person;
permit us to use that person's data to conduct a search with the credit reference agencies; and
permit us and/or the credit reference agencies to record or link information about you and that other person.

We use credit scoring as part of our assessment process. Credit scoring uses a number of factors to work out the risks involved in any application. A score is given to each factor and a total score obtained. Where automatic credit scoring computations are used, acceptance or rejection of your application may depend only on the results of the automatic credit scoring process. Where your application is rejected on the basis of information obtained from a credit reference agency (including where an automatic credit scoring process is used), we will notify you of the basis for our decision and provide you with the details of the relevant credit reference agency.

Where we have used automated credit scoring and your application is rejected, you have the right to object, within 21 days of our refusal of your application, to our use of automated credit scoring and may request that we reconsider the decision or take the decision on a different basis. If you do wish to request that we reconsider the decision, this request should be put in writing and sent to info@polarcredit.co.uk within 21 days of our refusal of your application. Objections received outside this 21 day period will not be considered.

You can find further information on the way credit reference agencies use and share your information at https://www.transunion.co.uk/legal/privacy-centre or https://www.experian.co.uk/legal/crain.

The Vulnerability Registration Service

The Vulnerability Registration Service (‘VRS’) is independent of any credit reference agency. Its sole purpose is to protect consumers and provide organisations with a tool to complement their regulatory and social responsibilities around dealing with vulnerable people at a particular point in their lives.

APFIN LTD is a participating member of the Vulnerability Registration Service (www.vulnerabilityregistrationservice.co.uk) and we may search the Register when assessing your application and managing your account with us.

Where you have given us your consent to do so, we will also register any vulnerable circumstances that you would like members of the VRS to be aware of. This will then allow other members of the VRS to take your personal situation into account without you having to explain it to them again.

Retention Period

We will hold the data that you provide for as long as permitted for legitimate business purposes.

We store your data for the following reasons:

• To respond to any questions or complaints;
• To show that we treated you fairly;
• As a record of your application to comply with statutory obligations in relation to FCA regulations;
• For legal reasons.

We will store your data, but no longer process it if you revoke your consent to receiving the offer of the services of other companies within the APFin Limited family, and other related services, including but not limited to, price comparison websites, that we think may genuinely interest you.

Where we store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

All the information you provide us is stored in a secure computing environment protected by secure firewalls to try to prevent unauthorised access. Our website and database of information is held on a secure server. We also control access to any information you provide us so that it is only provided to people who need to see it. When we transfer any of your information it will be password protected.

Your rights

• Right to be informed

o We are obligated to provide fair processing information, typically through a privacy notice, and the information must be concise, transparent, easily accessible and provided free of charge.

• Right of access

o Individuals have the right to access their personal data and supplementary information.
o The right of access allows individuals to confirm that their data is being processed and to verify the lawfulness of the processing.
o We will provide a copy of the information free of charge, however an administrative fee may be charged if the request is manifestly unfounded or excessive.
o Information will be provided within one month of receipt, however we may extend the period by a further 2 months if the request is complex or numerous.
o Some information can be found in your Polar Credit account.

• Right to rectification

o An individual’s personal data can be rectified if it is inaccurate or incomplete.
o Data will be rectified within one month of the request, however we may extend the period by a further 2 months if the request is complex.
o Some information can be changed in your Polar Credit account.

• Right to erasure

o An individual can request the deletion or removal of personal data where there is no compelling reason for its continued processing.
o We may be unable to fulfil your request for a number of reasons, including: if we need to keep your data in order to respond to any questions or complaints you may have, to show that we treated you fairly, as a record of your application to comply with statutory obligations in relation to FCA regulations, or legal reasons.

• Right to restrict processing

o Individuals have a right to ‘block’ or suppress the processing of personal data.
o When processing is restricted, we are permitted to store the personal data, but not further process it.

• Right to data portability

o Individuals may obtain and reuse their personal data for their own purposes.
o The personal data will be provided free of charge, in a commonly used format.
o Information will be provided within one month of receipt, however we may extend the period by a further 2 months if the request is complex or numerous.

• Right to object

o Individuals have the right to object to processing based on legitimate interests or the performance of a task in the public interest; direct marketing; and processing for purposes of scientific or historical research and statistics.
o Individuals must have an objection on “grounds relating to his or her particular situation”.

• Rights related to automated decision making including profiling

o We can only carry out this type of decision-making where the decision is necessary for the entry into or performance of a contract.

• Right to withdraw consent

o Individuals may withdraw consent for us to process your personal data for marketing purposes at any time.
o You can exercise your right to withdraw consent by not ticking certain boxes on the forms we use to collect your data or by contacting us as below.

• The right to lodge a complaint with a supervisory authority

o Further details of this can be found in our Complaints Policy.

To request any of the above rights, please email info@polarcredit.co.uk or use our contact form on the Contact Us page.

Consequences of failing to provide your personal data

As your personal data is required for us to assess your credit application, if you fail to provide the requested personal data in your Polar Credit application form, your credit application cannot be approved.

Cookies

A cookie is a small text file, which often includes a unique identifier that is sent to your computer or mobile phone (referred to here as a "device") browser from a website's computer and is stored on your device's hard drive. There are various types of cookies which perform different functions, such as remembering the information you provide us in your application for credit or recording your browsing habits. The information recorded by the cookie is retrieved on the user's next visit to the site.

Most web browsers will accept cookies, but if you would rather that we did not collect data in this way you can choose to accept all or some or reject cookies in your browser's privacy settings. If you want to control the use of cookies then you can do so by changing your browser settings. Information on deleting or controlling cookies is available at www.AboutCookies.org. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our site.

On our site, cookies record information about your online preferences, remember information about you when you visit our site and compile statistical reports on website activity. Some cookies are used that are essential in order to provide our services to you.

Information supplied by cookies can help us to analyse the profile of our visitors and help us to provide you with a better user experience. Below we have set out the categories of cookies that we use on our website.

Strictly necessary cookies

These cookies are essential in order to enable you to move around the website and use its features, such as using the application form to continue to navigate the site when making an application. Without these cookies, services you have asked for, such as applying for a Polar Credit Line using the website, cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the Internet.

Performance cookies

These cookies collect information about how our visitors use the website, for instance which pages visitors go to most often, and if they get error messages from any web pages. They also allow us to record and count the number of visitors to the website, all of which enables us to see how visitors use the website in order to improve the way that our website works. These cookies do not collect information that identifies a visitor, as all information these cookies collect is anonymous and is only used to improve how our website works.

Functionality cookies

These cookies allow our website to remember choices you make (such as your login details) or to personalise your browsing experience. The information these cookies collect is anonymous. They do not gather any information about you that could be used for advertising or remember where you have been on the Internet.

Google Analytics

We also use Google Analytics which is a web analytics service provided by Google, Inc. It allows us to monitor usage of our site and we use the results in order to help us improve our site for users. Google Analytics uses cookies in order to collect this information. The information collected is in an anonymous format and will not identify you as an individual.

Disclosure of your information

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may disclose your personal information to third parties:

In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
If APFin Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of use or the terms and conditions of your credit agreement and other agreements; or to protect the rights, property, or safety of APFin Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Other websites

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to info@polarcredit.co.uk.

Date this privacy policy was last updated: 1st August 2022