Privacy Policy

1. The information we collect and when.

Personal information is any information that either alone, or in combination with other information, would identify a person as a living individual, for example your name and date of birth.

Personal information does not include “Aggregated Usage Data” which is anonymized and aggregated information on how people interact without website and Service. Aggregated Usage Data helps us understand how users interact with the service, so we can provide better features and customer service. In addition to collecting and using Aggregated Usage Data ourselves, we may share Aggregated Usage Data with third parties, including our customers, partners and service providers, for various purposes, including to help us better understand our customers’ needs and improve the Service as well as for advertising and marketing purposes. We do not share Aggregated Usage Data with third parties in a way that would enable them to identify you personally.

We only collect personal information that we know we will genuinely use and in accordance with the Data Protection Legislation. The type of personal information that we will collect on you, and you voluntarily provide to us as part of our usual business may include some or all of the following:

Your name and title
1. Address
2. Date of birth
3. Telephone number(s)
4. Email address
5. Credit referencing information including:
  - Marital status
  - UK residency status
  - Length of time at address
  - Sex and gender
  - Employment status and length of employment
  - Number of dependents (children)
  - Household income
  - Household expenditure
  - Rent/mortgage payments

Payment details (bank cards)
1. IP address

We may, in further dealings with you, extend this personal information to include purchases, services used, subscriptions, records of conversations and agreements and payment transactions.

You are under no statutory or contractual requirement or obligation to provide us with your personal information. However, we require at least the information above in order for us to deal with you as a potential customer in an efficient and effective manner.

1.1 The type of data we collect and the reasons why.

1.11 Credit Assessment: We collect personal and financial information from you and from creditreference agencies (CRAs) to help us carry out identity checks and to assess your ability to meet your financial commitments and to check that you are creditworthy.

Such information includes your current and recent addresses, whether you are on the electoral role, your date of birth, e-mail address and telephone number, about your employment and income, whether you are a home owner or tenant, personal data about bank accounts, credit cards, mortgages and other agreements that involve a credit arrangement like utilities and communications contracts (including mobile and internet) and how you are meeting your payments obligations to these organisations and whether you have any court judgments. We will also collect information about your UK residency status.

1.12 Prevent and detect crime: We collect personal and financial information from you and from CRAs and public or government bodies to help us to detect and prevent crime and fraud and to verify your identity under our anti-money laundering obligations.

1.13 Servicing of your contract: The information we collect will enable us to communicate with you about your rental contract, to service your account and any matters in relation to the products and goods supplied (for example, to deal with the return of the goods or if repairs are needed).

It will also enable us to set up a personalised customer log in account for you to view a summary of your account details, your contact information and products obtained.

The information we collect will also enable us to communicate with you via your television with personalised alerts and you can also access relevant information this way using the remote control, including accessing your payment history and basic account details and you can interact with us to make a payment, make a payment arrangement, make support requests and arrange a call back.

Your data will also be used by us to issue statements, to process your payments onto our systems, to contact you about any missing payments and to trace you. We will make a record of our communications with you and your account activity to help us to monitor and manage your account, check that we are providing an adequate service and to help us to deal with any complaints. We will collect information about your bank account or payment card to enable us to process your rental repayments.

1.14 Improve our services and products: We will use your information, for research, assessment and analysis (including market and product analysis) and to develop and improve our services to you and other customers.

1.2 The legal basis for processing your personal data

The UK’s data protection law allows us to process your personal data where we have a proper reason for doing so. Such reasons include to fulfil a contract we have with you, where it is in our legitimate interest, where we have a legal duty and when you consent to it.

1.21 We rely on the legitimate reason basis in respect of our credit assessment activities described above. We will also share your data with credit reference agencies. A legitimate interest is when we have a business or commercial reason to use your information and this is not unfairly against your interests.

1.22 We rely on the contract performance basis in order to take steps to enter into the rental contract with you and supply the goods and products, to service the contract and to enforce our rights and remedies under the contract.

1.23 We rely on the legal duty for processing by collecting information in order to prevent and detect crime and by sharing such data with credit reference and government agencies and authorities. We will also collect information necessary for us to maintain records as required by government and regulatory bodies.

1.24 We will rely on your consent where:

you request that we disclose your information to others,
1. in the event that we process any special categories of personal data at your request (for example data concerning your health), we will only record them with your explicit consent if they are relevant to the management of your account (for example if you have a medical condition which requires a bespoke approach to our dealings with you), and
2. to send you marketing communications (see below).

How we use your information.

2.1 To contact you, following your enquiry, reply to any questions, suggestions, issues or complaints you have contacted us about.

2.2 Make available our products and services to you.

2.3 Process your orders.

2.4 Take payment from you or give you a refund.

2.5 Personalise your shopping experience, for example we may provide you with details of products that match a product, which you may have rented, purchased or enquired about previously.

2.6 For statistical analysis and to get feedback from you about our products, websites, mobile apps, and other services and activities. For example, occasionally we may invite you to review a product or service you’ve used from us. If we do, it’s possible that we’ll use independent research and feedback providers to act on our behalf.

2.7 To power our security measures and services so you can safely access our website and mobile apps.

2.8 Help us understand more about you as a customer, the products and services you consume, so we can serve you better.

2.9 Contact you about products and services from us.

2.10 Provide you with online advertising and promotions.

2.11 Help answer your questions and solve any issues you have.

Who we might share your information with

We may give information about you and how you manage your account to the following organisations and where we do so shall take reasonable steps to ensure that your rights are protected and that they will keep the information confidential.

3.1 People who provide a service to us or are acting as our agents. This includes any organisation where we have decided to outsource all or part of the administration or servicing of your agreement including in respect of:

delivery fulfilment of the goods,
1. a third party that holds customer data on its servers for us, including back up data for our use,
2. debt collection and goods recovery,
3. a third-party intermediary to manage debit card processing (although they are not permitted to store, retain or use your billing information for any other purpose), and
4. third parties we use to carry out repairs or servicing to the goods and products supplied.

3.2 Our insurers, auditors and accountants, solicitors, consultants and other professional advisers.

3.3 Anyone to whom we transfer or may transfer our rights and duties under your finance agreement (for example if we were to sell your agreement to another funder company).

3.4 Any funders or investors (or prospective funders or investors) of our business.

3.5 Credit reference agencies and fraud prevention agencies (see below).

3.6 We may also give out personal information about you if we have a duty to do so in order to comply with any legal obligation (including with any Government agencies or regulators).

3.7 Where we use a Data Processor to provide part of our service, we have Data Processor Agreements in place. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us or further sub-processors who must comply with our Data Processor Agreement. They will hold your personal data securely and retain it for the period we instruct.

Credit Reference Agencies.

To assess a finance application, we will perform credit and identity checks on you with one or more CRAs. Please see CRA sites for details on how this process is managed.

https://www.callcredit.co.uk/crain

https://www.experian.co.uk/crain/index.html

https://www.equifax.co.uk/crain/

Marketing

We will send you relevant offers and news about our products and services in a number of ways including by email, but only if you have previously consented to receive these marketing communications. When you register with us, we will ask if you would like to receive marketing communications, and you can change your marketing choices online, over the phone or in writing at any time.

If you wish to amend your marketing preferences, you can do so via your account or via the contact details below.

Your rights over your information

6.1 The right to be informed about our collection and use of personal data

You have the right to be informed about the collection and use of your personal data. We ensure we do this with our internal data protection policies and through our external website policy. These are regularly reviewed and updated to ensure these are accurate and reflect our data processing activities.

6.2 Right to Access Your Personal Information

You have the right to access the personal information that we hold about you in many circumstances, by making a request. This is sometimes termed ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you (or someone else on your behalf), we will provide it to you or them free of charge and aim to do so within 1 month from when your identity has been confirmed.

We would ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information.