APFIN LTD trading as Polar Credit ("We") are committed to protecting and respecting your privacy.
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:
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
Purpose for processing your data
We use your data in the following ways:
For the purposes of fulfilling your application to borrow money from us, we may pass your data to:
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), 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 or any lender that has approved your application for the purpose of progressing your application with them.
• Stop Go Networks Limited (FCA reference number 729572), 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 Stop Go Networks or any lender that has approved your application for the purpose of progressing your application with them.
The panel that can consider your application if your application with us is unsuccessful includes: T Dot UK Limited, 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.
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:
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 email@example.com within 21 days of our refusal of your application. Objections received outside this 21 day period will not be considered.
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.
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
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.
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.
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.
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.
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.
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.
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:
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.