Privacy and You
Who We Are
Peeled Finance Ltd (‘we’ or ‘us’ or ‘our’) operates www.peeled.io and gathers and processes your personal data in accordance with this privacy notice and in compliance with relevant data protection law and implementing legislation such as the Data Protection Act 2018. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why, and when we process your personal data. Our registered office is at St James’ House, Adelaide Road, Dublin 2. (Company No. 614386)
What?
Peeled Finance provides services to businesses so that they can offer digital consumer finance to their customers. This includes the capturing and verification of personal application data to enable them to verify their customers quickly and securely and arrange loans.
Who this applies to?
The following are categories of individuals to whom this privacy policy applies to and are referred to as you:
– Client – means a business and their users who are using the services in relation to our technology, with whom we may also share Customer’s personal information.
– Applicant – means an individual who uses the services in relation to their dealings with our Client.
– Customer – means a customer who is using the services in relation to our technology.
– User– means any person accessing our website
How is data collected?
- Where you supply information online through our technology.
- When you or others give us information verbally or in writing. This information may be on application forms, in records of your transactions with us or if you make a complaint.
- From your online activities with third parties where you have given us your consent (for example, by consenting to our use of certain cookies or other location tracking technologies).
- Fraud prevention agencies or public agencies or authorities, companies’ registrations agents, or judgement registries;
- Device data (such as type of device, operating system, IP-addresses, and advertising ID’s).
Purposes of Processing and Legal Basis
The purposes and reasons for processing your personal data are detailed below:
- to provide you with our services;
- to correspond in communications, as necessary;
- to complete identity and fraud prevention checks;
- to enable the completion of credit rating checks;
- to facilitate the communication between customers and the Lender;
- to comply with our legal obligations;
- to send promotional and marketing materials, subject to any preferences expressed when we collect any contact details or subsequently. You can opt out of receiving promotional and marketing materials from us at any time by contacting us.
The legal bases on which we process your personal data are:
- that this is necessary for the performance of a contract between you and the Lender or in order to take steps at your request prior to entering into the contract;
- that this is necessary for compliance with a legal obligation that applies to us, including for anti-money laundering, counter terrorist financing and fraud prevention;
- that this is necessary for the purposes of our legitimate interests in marketing and promoting our products and services, preventing identity fraud and conducting our business in a responsible and commercially prudent manner. We will not process your personal data for these purposes if such legitimate interests should be overridden by your own interests, rights and freedoms;
The legal basis on which we collect, process and transfer special categories of data relating to you in the manner described above are;
- that you have given your explicit consent to such processing.
Your Rights
At any point while we are in possession of or processing your personal data, you, as the data subject, have the below rights:
Right of access – you have the right to request a copy of the information that Peeled Finance possesses about you, including; what data we hold, the purposes of the processing, type of data, who we disclose it to, how long we will store it and where we obtained it. You can request a copy from our Data Protection Officer by email.
Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete. You can ask us to correct and/or complete your personal data and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records. Any personal data related to financial transactions is excluded from this right as we have an obligation to retain this information for at least 5 years due to anti-money laundering laws.
Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
Right of portability – where our processing of your personal data is based on you having provided consent or is necessary for the performance of a contract with you, you have the right to have the data we hold about you transferred to you or to another service provider in electronic form so that you can store and reuse your personal data for your own purposes across different services. We will not be in any way accountable or liable for any damage, loss or distress sustained, incurred, or suffered by you and/or the designated service provider as a result of improper use of the personal data upon and after receipt from us.
Right to object – you have the right to object to certain types of processing such as direct marketing.
Right to object to automated processing, including profiling –You have the right to be informed about any automated decision-making that may be used and can appeal any decisions made where the decision has a significant legal effect on you.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
Sharing and Disclosing
Peeled Finance uses third-parties for services and business functions. We have taken appropriate measures to ensure that all third-parties acting on our behalf only process personal data in accordance with our instructions and comply fully with this privacy notice and relevant data protection law.
We may need to share your information with certain third parties in connection with the above purposes, including:
- Our Clients;
- Identity Verification Provider;
- Fraud Screening Solution Provider;
- Credit Reference Agencies;
- Payment Service Provider;
- Where applicable, The Police or other law enforcement authorities to comply with requests for information in relation to investigations; and
- any third parties whom you ask us to share your information with.
Transfers Outside the EEA and UK (if applicable)
Some of our service providers, including payment processors, identity verification solution providers or suppliers may be based outside of the UK or outside the EEA, including in jurisdictions which are not recognized as providing for an equivalent level of protection for personal data as is provided for in the EU GDPR or UK GDPR. Where we authorise the processing or transfer of your personal data outside of these areas, we will ensure that there are acceptable safeguards in place to comply with our obligations under applicable laws governing such transfers.
These may include entering into a contract governing the transfer that contains the ‘standard contractual clauses’ approved for this purpose.
If you would like to receive further details of the measures that we have taken in this regard, please contact our Data Protection Officer.
Implications of Not Providing Your Data
You are not under a statutory or contractual obligation to provide your personal data to Peeled Finance, however, as this information is required to meet our legal obligations, and to be able to provide a service to you or our Client, we will not be able to offer our services without it.
How Long We Keep Your Data
Peeled Finance only ever retains personal data for as long as is necessary and we have strict review and retention policies in place to meet these obligations. Where required under anti-money laundering laws, we may keep your personal data for a minimum of 5 years after the business relationship ends, after which time it will be destroyed. Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.
Lodging A Data Complaint
Peeled Finance only processes your personal data in compliance with this privacy notice and in accordance with the relevant data protection law. However, if you wish to raise a complaint regarding the processing of your personal data or if you have any questions about how your personal data is gathered, stored, shared, or used, or to exercise any of your data rights, please contact our Data Protection Officer.
If you are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the local supervisory authority.
In the UK:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF.
Phone the helpline on 0303 123 1113. or via live chat service ico.org.uk/live chat. For further information please visit -. https://ico.org.uk/make-a-complaint/
In Ireland:
Data Protection Commission,
Canal House, Station Road,
Portarlington,
Co. Laois,
R32 AP23,
Ireland.
Phone +353 (0761) 104 800 | LoCall 1890 25 22 31 email info@dataprotection.ie or go to
https://forms.dataprotection.ie/contact