Privacy Policy

1. Who are we?

We, (Uplift Money Ltd) are an appointed representative of Digitonomy Limited, a credit broker authorised and regulated by the Financial Conduct Authority (“FCA”) (FRN 690249). We provide a mobile phone application (“Our App”) which allows customers to connect their bank account using Open Banking in order to report their rent payments for the purpose of building their credit history and improving their chances of eligibility for certain financial products. To provide our open banking journey, we are partnered with Tink AB Limited (FRN: 988456) who are authorised and regulated by the FCA to provide payment initiation and account information services.

Our registered office is The Steam Mill Business Centre, Steam Mill Street, Chester, CH3 5AN and our registered company number is 13159729. We are registered with the Information Commissioner's Office with registration number ZA880269.

2. Why do we have this privacy policy?

The purpose of this privacy policy is to give you a clear explanation about how we use the personal information we collect from you when you use Our App. It is important that you read it in full to understand the information we need to collect from you, how we will use it and how you can access, update and delete your personal information. It should be read together with our Terms and Conditions.

If you are re-directed to or click on a link that takes you to a third-party website that is not ours, we will not be responsible for how they use your personal information. You should read their privacy policy to understand how they may use your personal information. Other than the information in section 8 (“Who do we share your personal information with?”), this privacy policy only explains how we will process your personal information.

“Personal information” in this policy means any information that we collect that could identify you such as for e.g. your name, address and online identifiers like your IP address.

3. Our Service

When you use Our App for the first time, you will need to create an Uplift Money account. We will need some of your personal information to do this.

If you are a tenant (rather than a homeowner), you can use Our App to report your rent to Experian, a credit reference agency. Reporting your rent can help to improve your credit history which may increase your chances of being eligible for credit products, particularly if you haven’t had many credit agreements in the past. To use this aspect of Our Service, you will need to:

  • Confirm your address, the duration of time you have lived at your address and your home status
  • Confirm your rental due date, the amount of rent you pay and the payment frequency, and
  • Identify rental payments from your bank account transactions.

We will share this information ("Rent Reporting Information"), with Experian. Where we are unable to successfully identify rental payments (for eg if you have failed to make a payment), we will not report this to Experian and this will not affect your credit score. Please see section 8 ("Who do we share your Personal Information with?") for more Information about this aspect of Our Service.

So that we can identify your rental payments, you will need to allow Uplift Money to view your banking transactions and other banking data in a process known as Open Banking. We use Tink AB as our Open Banking provider. You will be asked to provide your consent before being securely connected through to your bank to access your bank account(s) on-line using their usual strong customer authentication process. Tink AB will present you with their privacy policy and terms and conditions which will explain how they will process your data.

You will then be returned to Our App where we will have downloaded and processed your Open Banking data, although this will not be visible to you.

The first time that you use Our Service, we will download your banking data from the previous 2 years. For subsequent connections, we will download banking data from the previous 90 days.

Unless you contact your bank to withdraw your consent, we will re-fresh your Open Banking data each month 1 day after the date upon which you pay your rent. After 90 days we’ll ask you to renew your consent to carry on reporting your rent. If you don’t do this, your consent will expire and we’ll ask you to reauthorize your Open Banking connection through our partner Tink AB. This will reconnect your bank account and we’ll begin to receive your Open Banking data again.

By using Our App and connecting your bank account, we will be able to confirm that you have made each month’s rent payment so that we can report it to Experian for it to be added to your credit file.

We are a data controller in relation to the personal information we receive about you when you use Our App, and we store this in data centres in the UK and EU.

We will present you with the opportunity within Our App to apply for other products and services such as credit cards, personal loans, bank accounts and credit building tools. We do this by partnering with Creditec Limited, another company within our Group. If you choose to search for one of these products via Creditec, your personal data will not be shared with Creditec.

Using the information you provided to us, we will stay in contact with you by providing you with a copy of the results of any search you may make for a product or service whilst using Our App. If you have given you consent, we will also send you marketing information about other products and services.

4. Ways you can contact us

You can contact us at any time by using one of the methods listed below, if you wish to know more about how we use and store your personal information:

Uplift Money Ltd,

The Steam Mill Business Centre,

Steam Mill Street,

Chester,

CH35AN

5. How do we collect your personal information?

This is information specific to you such as, but not exclusively, your name, address, telephone number, date of birth, financial account information, online identifiers (i.e. IP address).

We collect your personal information in the following ways:

  • If you indicate interest in Our App when using a website operated by another member of our group of companies (for e.g. www.little-loans.com or www.thimbl.com), some of your personal information will be shared with us. We use this information so that we can send you an SMS or email you a link to download Our App from either Google Play or the App Store.
  • When you register to use Our App. We use this information to validate your identity, create and secure account and provide Our Service.
  • When you use Our App. We use this information to enable you to use our rent reporting feature.
  • When you connect your bank account we receive your Open Banking data via our partner Tink AB. We use this information to report your rent payments to Experian and to provide Our Service.
  • Interact with us using social media such as Twitter, Facebook or Messenger etc.
  • Via automated technologies such as Cookies. Please see our Cookie Policy for further details.
  • Technical data about your equipment, browsing actions and patterns.

6. What personal information do we collect?

To enable us to provide Our Service, we need to collect the following information:

  • Identity information includes your title, first name, surname and date of birth.
  • Contact information includes your address, email and mobile telephone number.
  • Open Banking data includes your bank account and sort code, the balance on your account(s), your banking transactions (including date, description, transaction type, category amount and currency. This information is stored to a unique user ID and is encrypted within our database only. We will not share this information with anyone else or with any other platforms in our company or beyond.
  • CRA information includes information about your financial status and eligibility we receive from other members of our group of companies who may carry out a soft search on you if you apply for a financial product or service whilst using Our App.
  • Rent Reporting information includes Information about your rental/tenancy agreement Including your address, the time spent at your address, the amount of rent you pay and when it is due. You will need to confirm which transactions from your Open Banking data are for renting your property.
  • Technical information includes your internet protocol (IP) address used to connect your computer (or device) to the internet; your browser; time zone setting; your operating system and platform; the source of your enquiry (for example Google, Facebook, Bing etc) and the device you are using. We also collect information about your visit to our app including the full Uniform Resource Locators (URL) clickstream to, through and from our app (including the date and time); page response times, download errors; length of visits to certain screens; screen interaction information (such as scrolling and clicks) and methods used to navigate away from the screen.

7. Our legal bases for processing your personal information

To help you understand the ways in which we will use your personal information, and which of the legal bases we are relying upon to do this, we have detailed the following uses. Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information.

Purpose

Lawful basis for processing, including the basis of legitimate interests

Data Used

To send you communications to help you finish your registration with Uplift Money

Legitimate interest

Contact data

To register you so that you can use Our App

Performance of a contract

Personal details including: name, date of birth, email address, mobile number

 

To communicate with you about your account and the features and benefits of Uplift Money and to improve your experience of using Our App

Consent

Personal details including: name, date of birth, email address, mobile number

To provide the rent reporting feature to you and share your information with Experian

Consent

Rent reporting data including: address, time at address, living situation (i.e. homeowner status), information relating to tenancy arrangement

To provide customer support and maintain your account

Performance of a contract

Personal details including: name, date of birth, email address, mobile number

Rent reporting data including: address, time at address, living situation (i.e. homeowner status), information relating to tenancy arrangement

To monitor and continuously improve Our App

Legitimate interests – we need to be able to track how customers are interacting with Uplift Money to identify areas where we can improve performance or functionality (business or technical)

Behavioural data, including the number and nature of clicks and interactions

To carry out research for future iterations of Our App (for example, to model matrices whilst developing a scoring system for the Uplift Money Score)

Legitimate interests

Open Banking Data

To provide you with updates about our product and service via email, SMS or push notification

Consent

Personal details including: name, date of birth, email address, mobile number

Rent reporting data including: address, time at address, living situation (i.e. homeowner status), information relating to tenancy arrangement

8. Who do we share your personal information with?

When you use Our Service, your personal information will be shared with the following third parties or categories of third party:

  • Tink AB Limited: to securely obtain your Open Banking data from your bank. We are an agent of Tink who are authorised by the FCA as an account initiation service provider
  • The Experian Rental Exchange - If you are a tenant and decide to allow Our App to report your rental payments, you acknowledge that information regarding your rental payments and track record as a tenant, will be shared with Experian Ltd. Experian will add this information to the credit reference data it holds about you and use it as a data controller, in accordance with its fair processing notice (a copy of which can be found by following the link below), including so that it can be used to assist other landlords and organisations to:
    • assess and manage any new tenancy agreements you may enter into;
    • assess your financial standing to provide you with suitable products and services;
    • manage any accounts that you may already hold, for example reviewing suitable products or adjusting your current product in light of your current circumstances;
    • contact you in relation to any accounts you may have and recovering debts that you may owe;
    • verify your identity and address to help them make decisions about services they offer;
    • help prevent crime, fraud and money laundering;
    • screen marketing offers to make sure they are appropriate to your circumstances;
    • for Experian to undertake statistical analysis, analytics and profiling, and
    • for Experian to conduct system and product testing and database processing activities, such as data loading, data matching and data linkage.
    • If you would like to see more information on these, and to understand how the credit reference agencies each use and share rental data as bureau data (including the legitimate interests each pursues) this information is provided in this link: www.experian.co.uk/crain (Credit Reference Agency Information Notice (CRAIN)). (For a paper copy, please get in touch with us or with Experian using the contact details in this letter).

    • We will continue to exchange information about you with Experian while you have a relationship with us. We will also inform Experian when your tenancy has ended and if you have outstanding rental arrears Experian will record this outstanding debt. Experian will hold your rental data for the time limits explained in CRAIN (section 7). Rental data falls into the Identifiers (e.g. your name, address, date of birth) and financial account categories (i.e. tenancy account, rental payment information).

    • We and Experian will ensure that your information is treated in accordance with UK data protection law, so you can have peace of mind that it will be kept secure and confidential and your information will not be used for prospect marketing purposes.

    • If you would like advice on how to improve your credit history you can access independent and impartial advice from www.moneyadviceservice.org.uk (you can get a copy of your Statutory Credit Report by visiting www.experian.co.uk/consumer/statutory-report).

    • If you are unhappy with anything relating to Rental Exchange, please contact us on the contact details above. You also have the ability to get in touch with the Information Commissioner’s Office. More information about this can be found using this link here: https://ico.org.uk/concerns/.

  • Other companies who enable us to provide Our Service or who provide services to us, for example IT Service Providers (who provide for e.g. technology platforms or other IT services including data storage), and communication providers (who provide for e.g. email and text services for customer contact)

These third parties help us to provide Our Service. In order that they can do this, we may need to let them process your personal information. We will make sure that they keep the information secure and in accordance with our instructions, the UK General Data Protection Regulation ("GDPR") and other UK privacy legislation.

We’ll also share your personal information when we have your consent, or where we are obliged to do so for a legal or regulatory reason, for e.g. to prevent or detect crime, for compliance monitoring or to enforce or apply our Terms & Conditions and other agreements.

Finally, we may also share your personal information with any 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 information in the same way as set out in this privacy policy.

9. How long will we keep your personal information?

When you initially use Our App to connect to your bank, we will download Open Banking data from the previous 2 years which will be held in Our App. This will give you a longer-term view of your rent reporting trends.

The consent that you have given to your bank to share your Open Banking data with us lasts for 90 days. If you do not renew your consent after this period of time, your consent will expire and you will have to provide it again when you next use Our App. If you do not do this, we will begin to delete your personal information.

Unless we are required by law to keep your personal information for a different period of time, we will keep it for 365 days from the date that you last gave consent, or alternatively until you ask us to delete it.

10. Automated Decision Making

An automated decision is made by a computer or system to evaluate certain personal aspects relating to an individual to make a decision. We do not currently use automated processing or profiling to make decisions about you that could significantly impact you (like refusing you financial products or credit profiling), however, the providers of any financial products or services that you may apply for whilst using Our App will do this when we share your personal information with them so that they can make an assessment of your eligibility for that product or service.

Note: a 'soft search' is a search conducted by a credit broker or a lender with a credit reference agency such as Experian, Equifax or TransUnion. This helps them to determine whether or not they are able to provide the product or service. Unlike a 'hard' credit search, a soft search is recorded on your credit file but only you can see it, rather than any other finance provider. A 'soft search' does not impact your credit rating.

As a result, you have the right to ask the provider of any financial product or service that you apply for via Our App that they do not make a final decision based solely on automated means. You can also object to the automated decision and ask that a person reviews it. To exercise this right, you will need to contact the provider directly.

11. Is your personal information transferred outside the UK or the European Economic Area ("EAA")?

Although we do not routinely transfer personal information outside the UK or the EEA, we may sometimes need to do this where any of our Providers or third-party suppliers are either based outside the EEA, or where they use data processors based outside the EEA. Where this is the case, we’ll make sure that they agree to: keep your personal information secure; apply the same levels of protection as we are required to apply to information held in the EEA and to use it only for the purpose of providing Our Service. One of the ways we might do this is by putting in place appropriate safeguards and protections as stated under UK law, for example using a data-transfer agreement incorporating certain standard model protection clauses.

12. Data security

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

We have 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.

13. Cookies

Uplift Money utilises third-party cookies (which are provided by external entities and are not exclusive to Uplift Money) to monitor your visits to our App and track your interactions. By gaining insights into the most popular sections of our app and analysing where visitors spend their time, we can enhance overall performance for all users.

Furthermore, we employ third-party cookies to:

  • Assess the effectiveness of our advertising campaigns in encouraging individuals to download or access our App or visit our website.
  • Display advertising and content that pertains to Uplift Money.

The table provided below outlines the third-party cookies used by Uplift Money and the reasons behind their utilisation:

Who it serves

What it does

Bloomreach

Empowers us to monitor user sessions and deliver cross-platform push notifications, while also enabling us to recognize your past visits to our app for the purpose of delivering tailored content in the future.

Smartlook

Collects anonymized data on user interactions within our application to enhance our understanding and overall performance.

Sentry

Collects error data to help us improve our performance and response times to critical platform errors.

14. Your legal rights

  • Right to Withdraw Consent - you have the right to withdraw your consent at any time to any processing where we relied on your consent before carrying It out. To withdraw your consent, please see section 4 "Ways you can contact us." Any withdrawal of consent, will not affect the lawfulness of any processing based on consent before its withdrawal.
  • Right to Object - you have a right to ask us to consider any valid objections you have to our use of your personal data where we process it on the basis of our or a third party’s legitimate interest. You can object to this processing (including any profiling and/or direct marketing that we carry out) at any time by contacting us as detailed in Ways to contact us in section 4. We will action any request you make promptly, although this may mean that you may not be able to use Our App.
  • Right of Access - you can ask us whether we hold your personal information and if so you can access it by contacting us as detailed in section 4.
  • Right to Erasure - if it is no longer necessary for us to hold your personal information, bearing in mind the reason why you provided it to us, you can ask us to delete it. If you ask us to do this, we’ll complete your request as soon as possible although this will mean that we will not be able to help you find the financial product or service that you asked us to search for.
  • Right to Rectification - if we hold inaccurate personal information, you can ask us to correct it and we’ll action your request promptly.
  • Right to data portability - You have a right to ask us to provide your personal data to a third-party providerof services. in section 4.
  • Right to restrict our use of your information - you can ask us to restrict our processing of your personal information if you think, for example, that the personal information you gave us is inaccurate.
  • Right to complain to the Information Commissioner’s Office (ICO) - we’ll try to resolve any complaint that you may have in relation to data protection issues. If you are not happy with our final response you have the right to have your complaint dealt with by the ICO. See section 16 - “Complaints and contact details of our data protection officer.”

15. Complaints and contact details for our data protection officer

We want you to be confident that we are handling your personal information responsibly and in line with good practice. If you are concerned that we are not doing this, you should contact us immediately. We will treat your concern seriously and work with you to try and resolve it.

Please address your correspondence to:


The Data Protection Officer

Uplift Money Ltd

The Steam Mill Business Centre

Steam Mill Street

Chester

CH3 5AN


16. Changes to this policy

We will notify you by email and/or within Our App if we make any changes to this privacy policy.


Last updated 28/09/2023