Privacy Policy

We understand that protecting your personal information is of the utmost importance. This privacy policy explains how we, Intelligent Lending Limited (operating under the trading styles of Ocean and CredAbility) collect, use and store your personal information and how we ensure it is secure. Please read this policy carefully before using our website or mobile app or registering to use our service together with our Terms and conditions and Cookies Policy.

Intelligent Lending Limited is a Data Controller, which means that we determine the purposes and the means of processing your personal information. We are registered directly with the Information Commissioner’s Office (ICO) and our registration number is Z7306888.

This privacy policy will apply to you if you provide your personal information to us, even if you decide not to go ahead with any product or service we offer.

If you 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 data. You should read its own privacy policy to understand how they may use your personal data.

If you have any questions about how we may use your personal information you can contact us by using the details found on our website or in the Contact us section.

Date last updated:

1. What personal information do we collect?

The personal information we collect from you depends on the product you apply for, or the service that we provide to you. We will collect this information from you through websites and mobile applications. We will only collect information that we actually need, or where we’re required to collect the information to enable us to perform our legal or contractual obligations necessary to provide you with the products or services, or where we have your permission. We may also collect information via third parties.

The information we collect from your directly or about you from a third party may include the following:

  • Your personal details (for example, your name and date of birth)
  • Marital status
  • Your address and address history and general location
  • Your contact details (for example, your phone number and email address)
  • Special category personal information such as health information (see below)
  • Financial information (for example income and expenditure)
  • Residential Status (for example if you are a homeowner or tenant)
  • Property details
  • Employment information including occupation
  • Driving licence details
  • Vehicle details
  • Identification details such as DVLA licence number or passport
  • Energy and gas consumptions
  • Information on how you use our website, mobile app, products and services

Special Category Personal Information

We may collect special category personal information and that will depend on the product or service you are applying for.

The UK data protection law defines some personal information as “sensitive data” or “special categories of data”. This includes information about physical or mental health, sexual life, religious beliefs, race or ethnic origin, political opinions, trade union membership or biometric data (that is, computerised details used to identify you through your unique characteristics, for example through fingerprint scanning and facial recognition).

We may need to collect this information, for example, when you apply for an insurance quote, or if it may help us to provide you with a better service.  If we need to collect and process this type of information about you, by providing the information you are giving permission for us and any other third party to process this sensitive information as set out in this privacy policy. (We do not need your permission if we have to process this type of information by law). We can only use any personal information about you that relates to criminal convictions or offences if this is allowed by law.

Any personal information about you relating to criminal convictions or offences may only be used by us when authorised by law.

Information about other people

If you provide personal information about someone else, for example when a joint application is made, you must do so with the permission of the other person. If you apply for a product or service jointly with another person (for example, a joint loan application), both your personal information and the information of the joint applicant, including any information about the service provided may be shared with the other person.

We will use the personal information about the other person only in the ways as described in this privacy policy.

2. How do we collect your personal information?

We can collect your information in a number of ways.

  • When you make an application or enquiry to us either by phone, email, our websites, by a third party or by any other means
  • Information received from a third party, for example when we run checks with a third party, such as a credit reference agency or fraud prevention agency, or where you have previously agreed for your information to be shared with us, for example, if you have been introduced to us by another company
  • When you participate in market research, competitions and promotions provided by us, or on our behalf
  • By adding reviews or interacting with us using social media such as Twitter or Facebook etc
  • When we may need to obtain up to date information about you to meet our legal or regulatory obligations
  • Where you have given permission for your information to be provided to us
  • We may receive information from other people if you give permission for them to give us your information
  • We may also collect technical information about you based on your use of the website or mobile app, for example each time you visit the website or use the mobile app, your (IP) Internet Protocol address, browser type and version, products and services you viewed or searched. For more information please read our Cookies Policy

3. How we use your personal information?

We can only use your personal information where it falls into one or more of the following categories:

  1. it is necessary to enter into or fulfil a contract we have with you or which you have requested to enter into;
  2. you have provided your consent;
  3. we have a legal or regulatory obligation to do so;
  4. it is necessary to carry out a task which is in the public interest;
  5. it is necessary to protect your vital interests; or
  6. it is in our legitimate interest to do so and it is not against your rights.

How your personal information will be used will depend on the product or service being provided to you. You can select from the products below to see how your personal data will be used. If you decide not to go ahead with any of the services we offer and/or provide we will still process your personal information we have collected for the purposes set out in Other Purposes for Processing your Personal Data.

Credit Report and Credit Score

As part of CredAbility’s services we provide you with access to your online credit reports and credit scores, and access to offers of financial products and services. So that we can provide these services to you and administer your CredAbility account, we need to collect and process your personal information as set out below.

What personal information do you need to collect?

CredAbility will need to collect the following categories of personal information.

  • Personal information - such as your name, current and previous address(es) and date of birth, marital status, so that you can be correctly identified
  • Contact details – including your email, phone number and address so that we can contact you about your account
  • Residential status – such as if you are a homeowner, or tenant
  • Employment status – including occupation
  • Financial details – such as your income and spending and other details to allow us to promote relevant products to you

We need to collect the information above so we can check your registration, activate and maintain your account, and meet the obligations we have by law.

Who will you share the information with?

To provide your credit report, credit score and tips, with your prior permission, we will share your information with Equifax Limited (“Equifax”) (a credit reference agency) and we will receive information about you, and anyone you may have a financial association with (e.g. a joint mortgage or joint bank account), from Equifax, including for the purposes of obtaining a copy of your credit report on your behalf.  Equifax will record a soft footprint on your credit file that we have requested and obtained a copy of your credit report and this search footprint will be visible only to you.

For more information about how credit reference agencies may use your personal information, you can read the Credit Reference Agency Information Notice here or you can ask the three main credit reference agencies (TransUnion UK (formally Callcredit), Equifax and Experian) for a copy. You can also read Equifax’s privacy policy here: https://www.equifax.co.uk/ein.html

Fraud detection agencies working to prevent fraud within financial services.

CredAbility’s regulators (for example, the Financial Conduct Authority, the Information Commissioner’s Office or any other regulatory body or authority) may ask for certain information as part of supervising us. We have a legal or regulatory obligation to provide this.

How long will you store my information for?

While you continue to be our customer, we will keep a record of your personal information, including your credit score, to make sure that we provide you with the best service possible and if we have to keep it to meet the obligations we have by law or under any regulations that apply.

We will keep a copy of your credit report for the current month, after which time we will delete this information and replace it with your most recent credit report.

We will normally keep your information for at least 6 years, starting from the date when we are no longer providing you with a service.  We will keep records of phone calls for at least 6 years from the date of the call.

After this time, where we no longer need to retain your personal information for legitimate purposes, we will delete the information or remove your personal details from it so that it cannot be linked back to you.

Shield

As part of CredAbility’s service we provide you with a free Cyber check. This service helps identify if your email address (the email associated with your CredAbility account) has been compromised in any recorded online data breaches.  So that we can provide this service to you and send notifications, we will process your personal information as set out below.

What personal information will we need to process?

CredAbility will need to process the following categories of personal information.

  • Email address - Your associated email address with your CredAbility account

We need to process the information above so we can check your email address to provide you with notifications and to meet the obligations we have by law.

Who will you share the information with?

To provide you with this Cyber check service, we will share your email address with our Cyber check partner ‘Superlative Enterprises Pty Ltd’ trading as ‘How have I been pwned’ (HIBP)  ABN 62 085 442 02057 Admiralty Drive, Surfers Paradise, QLD 4217 Australia.

They will check your email address against their database to identify if your email account has been compromised in any recorded instances relating to data breaches. For more information on how they process your data please see their privacy policy.

How long will you store my information for?

While you continue to be our customer, we will keep a record of your recorded breaches (if applicable) to make sure that we provide you with the best service possible.

We will normally keep your information for at least 6 years, starting from the date when we are no longer providing you with a service.

After this time, where we no longer need to retain your personal information for legitimate purposes, we will delete the information or remove your personal details from it so that it cannot be linked back to you.

Personal Loans and Credit Cards

Ocean and CredAbility can introduce you to a credit broker who can find loans or credit cards from a preferred panel of lenders, as well as panels managed by other brokers or a lender. So that we can introduce you to our credit broker partner to provide these services to you, we need to collect and process your personal information as set out below.

What personal information do you need to collect?

To help you find a loan or credit card deal, we will need to collect the following categories of personal information.

  • Personal information - such as your name, current and previous address(es), marital status and date of birth so that you can be correctly identified
  • Contact details – such as your email address and phone number so that you can be contacted about your application or enquiry
  • Residential status – such as if you are a homeowner or tenant
  • Employment status – including occupation
  • Financial details – such as your income and spending and reason for borrowing

We need to collect the information above so that you can enter into the loan/credit card agreement with the lender and to meet our legal obligations.

Who will you share the information with?

We can help you find a loan or credit card deal by introducing you to a lender or a broker who has a preferred panel of lenders, as well as panels managed by other brokers. To make the offers we find more relevant to you, we share information with the brokers and lenders, who can run a soft search. (You can see a soft search on your credit report, but other lenders cannot see it and it does not affect your credit score.) The brokers and lenders may use the information they receive from the search to carry out analysis to help them provide you with better products and services in the future, to build customer profiles, and to assess whether you are likely to be accepted for a product.

If you apply for credit, the lender may share your personal information with credit reference agencies. This can include your personal details, public information (such as information on the electoral register), information about credit applications you have made, your financial situation and history and details of any joint credit commitments. This is so they can check your identity and creditworthiness (how likely it is that you will be able to repay the credit). This search carried out by the lender may be seen by other lenders, who may also use it to help make credit decisions about you, to prevent fraud and money laundering and to trace debtors.

If you make a joint application for credit, information about both of you and the outcome of any searches will be shared by the credit reference agencies and will appear on each person’s credit file.

We need to share information with lenders and brokers so that they can enter into a contract with you, to meet the obligations we have by law or under any regulations that apply, and if it is in our legitimate interests to do so.

For more information about how credit reference agencies may use your personal information, you can read the Credit Reference Agency Information Notice here or you can ask the three main credit reference agencies (TransUnion UK, Equifax and Experian) for help.

If you go on to apply for a loan with a lender, you should also read their privacy policy to see how they will use your personal information.

Our regulators (for example, the Financial Conduct Authority, the Information Commissioner’s Office or any other regulatory body or authority) may ask for certain information as part of supervising us. We have a legal or regulatory obligation to provide this.

How long will you store my information for?

While you continue to be our customer, we will keep a record of your personal information to make sure that we provide you with the best service possible and if we have to keep it to meet the obligations we have by law or under any regulations that apply.  We will normally keep your information for at least 6 years, starting from the date when we are no longer providing you with a service. We will keep records of phone calls for at least 6 years from the date of the call.

After this time, where we no longer need to retain your personal information for legitimate purposes, we will delete the information or remove your personal details from it so that it cannot be linked back to you.

Ocean Credit Card

Ocean Finance are a credit broker and Capital One is the exclusive lender. The Ocean credit card is issued by Capital One plc. So that we can provide this service to you, we need to collect and process your personal information as set out below.

What personal data do we need to collect?

If you apply for an Ocean credit card we will need to collect the following categories of personal information:

  • Personal information - such as your name, current and previous address(es) and date of birth so that you can be correctly identified
  • Contact details – such as email address and phone number, so that you can be contacted about your application or enquiry
  • Residential status – such as if you are a homeowner or tenant
  • Your income and expenditure, including employment details – so that your affordability can be calculated
  • Financial details – to arrange for any payments to be set up

This is required to enable a credit card agreement with Capital One plc to be entered into with you and to fulfil our legal obligations.

Who will the data be shared with?

If you apply for the Ocean credit card your personal information will be shared with Capital One who issue the Ocean credit card.

Before you apply for an Ocean credit card, if you agree we can share your personal data with Credit Reference Agencies (CRAs) to carry out a QuickCheck to see the likelihood of whether your application would be accepted. This check would appear on your credit report but would only be visible to you. You can read the QuickCheck terms and conditions here.

Capital One will review the information provided to assess your application and decide whether they will be able to provide you with an Ocean credit card. If successful Capital One will then process your personal data for the purposes of providing and administering your Ocean credit card. You can view Capital One’s privacy policy here.

If you don’t meet the criteria for the Ocean credit card we will carry out an additional ‘soft’ credit search with CRAs to assess your general suitability for other products that we may be able to provide. We may also share your personal data with CredAbility who will search their panel of lenders to try and find you a suitable credit product. This search will only be seen by you and will not affect your credit score.

For further information on how CRAs may use your personal information you can view the Credit Reference Agency Information Notice here or from the three main CRAs – TransUnion UK; Equifax; and Experian.

Ocean's regulators, such as the Financial Conduct Authority, the Information Commissioners Office or any other regulatory body or authority may request certain information as part of supervising us. We have a legal or regulatory obligation to provide this.

How long will your data be stored for?

If you successfully apply for the Ocean credit card, we will keep a record of your personal data to ensure that we provide you with the best service possible and where we’re required to keep your personal information to meet our legal and regulatory obligations. This will normally be kept for at least 6 years, starting from the date when we are no longer providing you with a service. Telephone calls will be retained for at least 6 years from the date the call was made.

After this time, where we no longer need to retain the data for legitimate purposes, we will delete the information or anonymise the data so that it cannot be linked back to you.

Car Finance

Ocean and CredAbility can introduce you to our credit broker partner who can provide you with various car finance options from a preferred panel of lenders as well as panels operated by other brokers. To allow us to provide these services to you, we will be required to collect and process your personal data as set out below.

What personal information do you need to collect?

To help our broker partner find a car finance deal from their panel of lenders as well as panels operated by other brokers, we will need to collect the following categories of personal information:

  • Personal information - such as your name, current and previous address(es) and date of birth, so that you can be correctly identified
  • Contact details – such as email address and phone number, so that you can be contacted about your application or enquiry
  • Vehicle details – so that the necessary vehicle checks can be made
  • Driving licence type - for example, Full UK, Provisional, EU, and International
  • Residential status – such as if you are a homeowner or tenant
  • Employment details – including your occupation
  • Financial details – such as your income and spending and to arrange for any payments to be set up

This is required to enable the Car Finance/Loan agreement to be entered into with you and to fulfil our legal obligations.

Who will the data be shared with?

We can help you find a car finance deal by introducing you to our credit broker partner who has a preferred panel of lenders as well as panels operated by other brokers. We and/or the lender may share your personal information with Credit Reference Agencies (CRAs) when a credit search is carried out. This can include information about your personal details; credit applications; public information, such as information on the electoral register; your financial situation and history and details of any joint credit commitments. This is to verify your identity and credit worthiness and the search may be seen by other lenders, where they may also use it to help make credit decisions about you, to prevent fraud and money laundering and to trace debtors.

If the application is joint, information about both applicants, and the outcome of any searches will be shared.

This is required to enable a contract to be entered into with you, to comply with our legal and regulatory obligations and where it is in our legitimate interests to do so.

We may also carry out a ‘soft’ credit search with CRAs to assess which lender(s) may be more suitable for your financial circumstances and to help find you the best solution.  This search will not be seen by other lenders and will not affect your credit score.

For further information on how CRAs may use your personal information you can view the Credit Reference Agency Information Notice or from the three main CRAs – TransUnion UK; Equifax; and Experian.

If you go on to apply for car finance deal through our credit broker partner and/or with a lender you should also read their privacy policy to see how they will use your personal information.

Our regulators, such as the Financial Conduct Authority, the Information Commissioner’s Office or any other regulatory body or authority may request certain information as part of supervising us. We have a legal or regulatory obligation to provide this.

How long will your data be stored for?

Whilst you continue to be our customer, we will keep a record of your personal data to ensure that we provide you with the best service possible and where we’re required to keep your personal information to meet our legal and regulatory obligations.  This will normally be kept for at least 6 years, starting from the date when we are no longer providing you with a service. Telephone calls will be retained for at least 6 years from the date the call was made.

After this time, where we no longer need to retain the data for legitimate purposes, we will delete the information or anonymise the data so that it cannot be linked back to you.

Mortgages

Ocean Finance are a broker and work with a panel of lenders to allow us to find you the best mortgage deal for your circumstances. Additionally, where we identify, based on your circumstances, that you may benefit from the service of one of our mortgage broker partners, we will introduce you to that broker to help find you a suitable mortgage. To allow us to provide these services to you, we will be required to collect and process your personal data as set out below.

What personal data do we need to collect?

To help us find you a mortgage from our panel of lenders, or to introduce you to one of our broker partners, we will need to collect the following categories of personal information:

  • Personal information - such as your name, current and previous address(es) and date of birth, so that you can be correctly identified
  • Contact details – such as email address and phone number, so that you can be contacted about your application or enquiry
  • Property details – so that the necessary property checks can be made
  • Your income and expenditure, including employment details – so that your affordability can be calculated
  • Financial details – to arrange for any payments to be set up

This information is required to enable the mortgage loan agreement to be entered into with you and to fulfil our legal obligations.

Who will the data be shared with?

Your personal data will be shared with lenders to enable us to find you a suitable mortgage deal.

We will share your personal information with Credit Reference Agencies (CRAs) to carry out credit searches which we’re required to do on behalf of the lender. We will do this to check your identity; check your eligibility for an account; and as part of our fraud prevention procedures. This can include information about your personal details; credit applications; public information, such as information on the electoral register; your financial situation and history and details of any joint credit commitments. The chosen lender may also carry out a search to verify your identity and credit worthiness. The CRA will add details of any searches to your credit record which can be seen by other organisations that make searches and they may use it to help make credit decisions about you, to prevent fraud and money laundering and to trace debtors.

If the application is joint, information about both applicants, and the outcome of any searches will be shared.

This is required to enable a contract to be entered into with you, to comply with our legal and regulatory obligations.

For further information on how CRAs may use your personal information you can view the Credit Reference Agency Information Notice here or from the three main CRAs – TransUnion UK; Equifax; and Experian.

Where you have provided us with your information, we may share your personal data and introduce you to one of our mortgage broker partners e.g. Mojo Mortgages, a trading style of Life’s Great Limited (and you may also be redirected to their website) to enable the broker to review your circumstances and to help provide you with a suitable mortgage.

If you go on to do business through one of our broker partners and/or with a lender you should read their privacy policy to see how they will use your personal information.

Ocean's regulators, such as the Financial Conduct Authority, the Information Commissioners Office or any other regulatory body or authority may request certain information as part of supervising us. We have a legal or regulatory obligation to provide this.

How long will your data be stored for?

Whilst you continue to be our customer, we will keep a record of your personal data to ensure that we provide you with the best service possible and where we’re required to keep your personal information to meet our legal and regulatory obligations. This will normally be kept for at least 6 years, starting from the date when we are no longer providing you with a service. We will retain telephone calls for at least 6 years from the date the call was made.

After this time, where we deem that we no longer need to retain the data for legitimate purposes, we will delete the information or anonymise the data so that it cannot be linked back to you.

Homeowner and Secured Loans

We can introduce you to brokers who work with a panel of lenders to allow them to find you the best homeowner/secured loan deal for your circumstances. So that we can introduce you to our broker partner to provide these services to you, we need to collect and process your personal information as set out below.

What personal information do you need to collect?

To introduce you to one of our broker partners and to help them find you a homeowner or secured loan from a panel of lenders we will need to collect the following categories of personal information:

  • Personal information - such as your name, current and previous address(es), marital status and date of birth so that you can be correctly identified
  • Contact details – such as email address and phone number so that you can be contacted about your application or enquiry
  • Property details – so that the necessary property checks can be made
  • Employment status – including occupation
  • Financial details – such as your income and spending – so that your affordability can be calculated and to arrange for any payments to be set up

This information is required to enable the loan agreement to be entered into with you and to fulfil our legal obligations.

Who will you share the information with?

We can help you find a homeowner loan/secured loan by introducing you to a lender or a broker who has a preferred panel of lenders, as well as panels managed by other brokers. To make the offers we find more relevant to you, we share information with the brokers and lenders, who can run a soft search. (You can see a soft search on your credit report, but other lenders cannot see it and it does not affect your credit score.)

The brokers and lenders may use the information they receive from the search to carry out analysis to help them provide you with better products and services in the future, to build customer profiles, and to assess whether you are likely to be accepted for a product.

If you apply for a homeowner/secured loan, the lender may share your personal information with credit reference agencies.  This can include your personal details, public information (such as information on the electoral register), information about credit applications you have made, your financial situation and history and details of any joint credit commitments.  This is so they can check your identity and creditworthiness (how likely it is that you will be able to repay the credit). This search carried out by the lender may be seen by other lenders, who may also use it to help make credit decisions about you, to prevent fraud and money laundering and to trace debtors.

If you make a joint application, information about both of you and the outcome of any searches will be shared by the credit reference agencies and will appear on each person’s credit file.

We need to share information with lenders and brokers so that we can enter into a contract with you, to meet the obligations we have by law or under any regulations that apply, and if it is in our legitimate interests to do so.

For more information about how credit reference agencies may use your personal information, you can read the Credit Reference Agency Information Notice here or you can ask the three main credit reference agencies (TransUnion UK (formally Callcredit), Equifax and Experian) for help.

If you go on to apply for a loan with a lender, you should also read their privacy policy to see how they will use your personal information.

Our regulators (for example, the Financial Conduct Authority, the Information Commissioner’s Office or any other regulatory body or authority) may ask for certain information as part of supervising us. We have a legal or regulatory obligation to provide this.

How long will you store my information for?

While you continue to be our customer, we will keep a record of your personal information to make sure that we provide you with the best service possible and if we have to keep it to meet the obligations we have by law or under any regulations that apply.  We will normally keep your information for at least 6 years, starting from the date when we are no longer providing you with a service. We will keep records of phone calls for at least 6 years from the date of the call.

After this time, where we no longer need to retain your personal information for legitimate purposes, we will delete the information or remove your personal details from it so that it cannot be linked back to you.

Energy Switching

CredAbility’s domestic online and telephone based energy comparison and switching service is supported by our trusted partner Fundraising Innovations Ltd (company number 04426857), trading as energyhelpline (registered address - The Cart Wagon Lodge, Friday Street Farm, Friday Street, East Sutton, Kent, ME17 3DD), who process data securely and in line with Data Protection regulations.

As a Data Controller, energyhelpline are responsible for capturing the information you enter into a switch application in order to forward it to your chosen supplier, to enable them to set up your new energy account(s). Once your data is passed to your chosen supplier they will process it in line with their Privacy Policy, which energyhelpline are not responsible for. For further information on how your data is processed please refer to the partner’s Privacy Policy on their website.

What personal information do you need to collect?

CredAbility will need to collect the following categories of personal information.

  • Personal information - such as your name, address, postcode
  • Contact details – including your email, phone number so that you can be contacted about your account
  • Property details – such as size and type
  • Energy details – such as your current provider, monthly usage, and monthly cost to allow the services to be provided to you
  • Financial details – such as sort code and account number to be able to set up direct debit payments

We need to collect the information above so we that necessary steps can be taken to provide you with energy comparisons from energy suppliers and to enable your new energy account to be set up and to meet the obligations by law.

When you run an energy comparison, we will use your information provided to continue to compare energy deals in the future

Who will you share the information with?

If you have requested to switch providers your personal data will be processed to support that process and will be shared with energyhelpline and your chosen supplier, based on your permission to do so.

How long will you store my information for?

While you continue to be our customer, we will keep a record of your personal information, to make sure that we provide you with the best service possible and if we have to keep it to meet the obligations we have by law or under any regulations that apply.

We will normally keep your information for at least 6 years, starting from the date when we are no longer providing you with a service.

After this time, where we no longer need to retain your personal information for legitimate purposes, we will delete the information or remove your personal details from it so that it cannot be linked back to you.

Broadband and Telecommunications

CredAbility work with a trusted partner, UK Web Media Limited (company number 04388827), trading as Broadband Finder and Mobile-Phones (registered office address - The Cart Wagon Lodge, Friday Street Farm, Friday Street, East Sutton, Kent, ME17 3DD), who can provide you with access to a comparison tool to make it easy to compare the latest broadband (including mobile broadband), fibre, home phone, TV and mobile phone deals from a range of UK providers. We will only direct you to their website and will not share any of your personal data with them. If you decide to apply for a product through UK Web Media Limited, they may provide us with personal information about you to help with our business development and for statistical purposes. You can read more about how UK Web Media Limited may process your personal information by reading their privacy policy on their website.

Debt Solutions

Ocean and CredAbility work with the Financial Wellness Group Limited and their companies, Debt Advisory Centre (a trading name of Gregory Pennington Limited) and Debt Free Direct (a trading name of Freeman Jones Limited), who can provide debt advice and products and services to help you get out of debt. If you are interested in these services, and if you agree, we’ll share your personal information with these partners to save you time when applying for their products. If you decide to take a product with Debt Advisory Centre or Debt Free Direct, they may provide us with personal information about you to help with our business development and statistical purposes. You can read more about how these partners may process your personal information by reading their privacy policies on their websites.

Personal Banking

CredAbility work with a partner, thinkmoney (a trading name of Think Money Limited), who offer personal current accounts. We will only direct you to their website and will not share any of your personal data with them, if you decide to apply for a product from thinkmoney, they may provide us with personal information about you to help with our business development and for statistical purposes. You can read more about how thinkmoney may process your personal information by reading their privacy policy on their website.

Business Banking

CredAbility work with a partner, Cashplus (a trading name of Advanced Payment Solutions Limited), who offer business accounts. We will only direct you to their website and will not share any of your personal data with them. If you decide to apply for a product from Cashplus, they may provide us with personal information about you to help with our business development and for statistical purposes. You can read more about how Cashplus may process your personal information by reading their privacy policy on their website.

Car Insurance

CredAbility works with a partner, Confused.com (a trading name of Inspop.com) who offer access to Car Insurance through an online comparison site. We will only direct you to their website and will not share any of your personal data with them. If you decide to apply for a product from Confused.com, they may provide us with personal information about you to help with our business development and for statistical purposes. You can read more about how Confused.com may process your personal information by reading their privacy policy on their website.

Ocean can introduce you to Quotezone (a trading name of Seopa Limited), an insurance broker, to enable you to obtain a competitive quote for motor insurance. If you request a quote for motor insurance your personal information will be collected and processed by Quotezone. Quotezone may share limited personal information about you and your quote with us to allow us to administer any promotions we may have in place when you take out an insurance policy through Quotezone.

What personal data do they need to collect?

To help our insurance broker find a competitive motor quote, we will need to collect the following categories of personal information on their behalf:

  • Personal information - such as your name, current and previous address(es)and date of birth, so that you can be correctly identified
  • Contact details – such as email address and phone number, so that you can be contacted in relation to your enquiry or application
  • Residential status – such as if you are a homeowner or tenant
  • Vehicle details – such as vehicle make, model, value, security and tracking devices
  • Driving licence type – for example, Full UK, Provisional, EU, and International
  • Employment details – including occupation
  • Any additional drivers – personal information for anyone who may be named to drive on the policy
  • Special category information – such as medical conditions and driving history offences or convictions
  • Financial details – to arrange for any payments to be set up

This is required to enable a Motor Insurance quote to be provided to you by Quotezone and to fulfil any legal obligations.

Who will the data be shared with?

This information will be collected and processed directly by Quotezone.

If you go on to apply for motor insurance quote you should also read their privacy policy to see how they will use your personal information.

Our regulators, such as the Financial Conduct Authority, the Information Commissioner’s Office or any other regulatory body or authority may request certain information as part of supervising us. We have a legal or regulatory obligation to provide this.

How long will your data be stored for?

Whilst you continue to be our customer, we will keep a record of your personal data to ensure that we provide you with the best service possible and where we’re required to keep your personal information to meet our legal and regulatory obligations. This will normally be kept for at least 6 years, starting from the date when we are no longer providing you with a service. Telephone calls will be retained for at least 6 years from the date the call was made.

After this time, where we no longer need to retain the data for legitimate purposes, we will delete the information or anonymise the data so that it cannot be linked back to you.

Home Insurance

CredAbility work with a partner, Confused.com (a trading name of Inspop.com) who offer access to Home Insurance through an online comparison site. We will only direct you to their website and will not share any of your personal data with them. If you decide to apply for a product from Confused.com, they may provide us with personal information about you to help with our business development and for statistical purposes. You can read more about how Confused.com may process your personal information by reading their privacy policy on their website.

Other purposes for processing your personal information

Websites, Mobile Applications and Marketing

To help us understand you better and provide you with information about other products which may be suitable and relevant, we will use your personal information to create a profile of you and your circumstances.  This allows us to provide more relevant, accurate and tailored services to you. For example, we may assess your income and spending to work out whether you may be able eligible to apply for a personal loan through us or our broker partners’ panel of lenders. We believe we have a legitimate interest to do this in accordance with your rights. We may then use the profile we have created to tailor any marketing communications to you. If you don’t want us to use your personal information in this way, you can contact us to let us know.

If you create a CredAbility account, there are types of information we will collect and process for the purposes of providing our services to you as agreed in our terms and conditions. This may include products you viewed or searched.

Reviews and Market Research

If we have a copy of your personal information, we or a third party research company acting on our behalf may contact you to ask you to provide a review of the services you’ve received or if we are carrying out market research which may help us design future products and services or help improve our current services. Although this information would really help us, you don’t have to provide it unless you’re happy to. We consider it is in our legitimate interests to contact you in this way for market research purposes.

Legal or Regulatory Obligations

We must process your personal information if we have to do this by law or under any regulations that apply (for example, to keep to anti-money laundering regulations).

Responding to Complaints or Enquiries

If you contact us with an enquiry or complaint, we will use your personal information to investigate the complaint and deal with your enquiry.  We have a legal and regulatory obligation to deal with complaints appropriately.

Analysis Purposes

As part of our legitimate interest to develop our business and our products, we will use your personal information to assess our performance as a business and to analyse statistics.  We will use as little personal information as we can to achieve this.  We may also share this analysis with third parties who provide us with services and if we have to share the information under a contract we have with them.

Location Information

To help you use some of our online services we may ask for your permission to use your current location, for example, to help you fill in an address if you need to do this to receive part of our service or on an application form.  You do not have to give us permission to use your location if you do not want to.  If you do allow us to use this information, we will only store it for the duration of your online session and we will not share it with anyone else.  When you use our website or mobile app we may also use information about your general location, for example the nearest town.  We may use this information for customer-analysis purposes.

4. Automated Decision Making

An automated decision is one which we rely on a computer or system to assess the information you provide to us to make a decision about you. This may include:

  • assessing your eligibility for a product or service, for example a credit check for a credit card or loan application
  • detecting any fraudulent activity which may be taking place, or there is a risk that it could take place
  • checking identity and residency statuses

If we do make an automated decision about you, in some cases you have the right to ask that we do not make our final decision based solely on the automated decision, and you can also object to the automated decision and ask that someone reviews it. If you want to do this you’d need to contact us, or use the contact information which will be provided to you once you’ve received the automated decision.

5. Who do we share your information with?

In addition to the companies, organisations and other third parties set out in Section 3, we may also share your personal information with the following organisations to help us provide our services:

  • IT Service Providers who provide IT platforms or other IT services
  • Payment Service companies that process transactions such as direct debits or card transactions (where applicable)
  • Communication providers (e.g. telephone line providers and email and text service providers)
  • Printers who print the letters and information packs which we send to you
  • Advertisers and social media companies such as Facebook, Google and Twitter for our social media accounts, advertising and profiling purposes, or where we can contact you using your social media account
  • Service Providers and Suppliers - In order to make certain services available to you, we may need to share your personal details e.g. to enable a supplier to send you an electronic gift card if you have taken part in a promotional campaign
  • Market Research companies such as Feefo to help us improve our products and services
  • Third party partners who may have introduced you to our services or where we may introduce you to, or promote their financial products or services. This may include fellow Think Money Group companies:
    • Think Money Limited, who provide current accounts and may also introduce you to us to help find a loan;
    • Your Loan Deals (a trading style of Think Money Limited) to allow them to search their panel of lenders and whom may also be able to introduce to you alternative financial solutions; and
    • Financial Wellness Group Limited and their companies, Debt Advisory Centre (a trading name of Gregory Pennington Limited) and Debt Free Direct (a trading name of Freeman Jones Limited) to allow them to provide you with suitable debt advice/solutions.

These companies help us to provide services to you. We will have a contract in place with any provider who directly provides us with such services to ensure that they comply with their data protection obligations and ensure that they have appropriate security measures in place. We regularly monitor our service providers to ensure they comply with our contractual obligations in relation to the processing and security of your personal information.

We may also share your personal information where we have your consent to do so or where we’re required to do so under a legal or regulatory obligation or court order, such as the police, local authorities or the courts.

6. Using Fraud Prevention Agencies

The personal information we have collected from you may be shared with fraud prevention agencies who will use it to prevent fraud, money-laundering and terrorist financing and to verify your identity. If fraud is detected, you could be refused certain services, finance or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found by contacting us or email us at [email protected]

7. Social Media

We use publicly available social media platforms to promote our services, to provide updates and to share any news and promotional updates. We may collect personal information from these social media platforms, for example, if you post a message on our Facebook page. By providing any of your information to us through these platforms you should be aware that:

  • the social media web pages are publicly available and you must not provide any personal or sensitive information on our pages that are accessible to the public, such as your account information. We may ask you for your account information via a private message to identify you and to service any request you make; and
  • each social media platform will process any personal information you provide through the platform and will be processed in accordance with its own privacy policy. The privacy policies are available to view on each social media platform.

8. International Transfers

We will only share your personal information outside the UK where we have your consent; to comply with a legal obligation; or where we work with a business partner to enable us to provide you with our services, and they process information outside of the UK.

If we do share any of your personal information outside of the UK, we will make sure that it is protected in the same way as if it was being used within the UK to ensure appropriate safeguards are in place. This may include putting in place a contract with the business partner that means they must protect the personal data to the same standards as it would within the UK (this may include model clauses), or only share the data to a business partner outside the UK or in a non-EEA country where the privacy laws provide the same protection as within the UK or the EEA or where appropriate technical and organisational measures are in place to ensure the data is protected and secure.

More information on this can be found on the Information Commissioner’s Office website.

9. Security

We take the protection of personal information very seriously and we will maintain appropriate measures to maintain the confidentiality, integrity and availability of the information you have provided. Such measures include:

  • company security policies and standards
  • staff security awareness
  • role based access controls to prevent unauthorised access to the information
  • encryption and anonymisation technology
  • anti-malware technologies
  • security monitoring
  • security testing
  • secure archiving and deletion
  • compliance with industry regulation and legislation

10. How we may contact you about the products and services we provide to you?

To help us keep you up to date about the products and services that we provide to you and to ensure that you’re kept fully informed, in line with relevant consent you have given, we may contact you by letter, telephone, email, text message or other electronic means.

If you start an application for a product or service through us we will attempt to contact you shortly after if you were unable to complete your application for whatever reason, to see if you wish to proceed.

If you enter into a product for a fixed period of time, for example a fixed term mortgage or an insurance policy, we may contact you to remind you that the product is up for renewal and/or discuss a renewal of the product where this may be available.

If you do not want to be contacted in a particular way then you can request this at any time, but if we are providing a service to you we do need to be able to send you communications. This can often be due to a legal or regulatory requirement.

It is important that you keep us up to date when you change your contact details or any other personal information, to ensure that we use your up to date contact information and that we use accurate information about you.

11. Your Rights

You have certain rights under data protection legislation. These include:

Access to your personal information

You have the right to request from us a copy of the personal information that we may hold about you. This is often called a “Data Subject Access Request”. You can request this information by contacting us as noted in the Contact Us section below.

Before providing this information to you or to another person or company where you have requested this personal information to be sent to, we may ask for proof of identity or ask sufficient questions to enable us to locate the information and ensure that we’re only providing it where you have given your agreement.

Right to have your personal information corrected

If the personal information we hold about you is incorrect you have the right to request that we correct this.

Right to stop or limit the processing of the data we carry out

You have the right to stop us from using your personal information or limit the way in which we process your information at any time if we are no longer entitled to do so. You may also request that your personal information is deleted. There may be occasions where we are unable to delete the data due to our legal or regulatory obligations however we will discuss this with you if you request for your information to be deleted.

Portability

In some cases you may be able to request for your information to be provided to yourself or another company in a format that can be processed electronically by yourself or the other company. If you want to request this you’ll need to contact us and we may ask for proof of identity or ask sufficient questions to enable us to locate the information and ensure that we’re only providing this information where you have given your consent to do so.

12. How long do we keep your personal information for?

Whilst you continue to be our customer or where you have successfully taken a mortgage, loan, credit card or other credit or insurance product, or any mobile/broadband/energy product, we will keep a record of your personal information to ensure that we provide you with the best service possible and where we’re required to keep your personal information to meet our legal and regulatory obligations. The product specific information will set out how long your personal information will normally be kept for.

Your personal information will normally be kept for at least 6 years, starting from the date when we are no longer providing you with a service. Telephone calls will be retained for at least 6 years from the date the call was made.

If you do not go ahead with any product or service offered by us, we would usually keep your personal information for at least 3 years where you have given your consent to receive marketing or promotional messages from us.

After this time, where we no longer need to retain the data for legitimate purposes, we will delete the information or anonymise the data so that it cannot be linked back to you.

13. Marketing communication and your marketing preferences

If you have provided us with your consent or where we have a legitimate interest to do so, we may contact you to let you know about other offers, products and services that we provide or that are provided by our third party partners (for example Think Money Limited) which we think you may be interested in or that may benefit you. We may do this through post, emails, text messages, telephone, push notifications, social media or other electronic means.

You can easily let us know at any time if you would no longer like to receive these marketing messages. You can contact us by using the details on our website, or unsubscribing using the link or information within recent marketing messages you have received from us. Alternatively you can opt out of receiving marketing contact by contacting us at: [email protected]

14. Other types of advertising

When you visit our website or similar financial service websites Google may use our advertisements promoting our products and services which may appear on other third party websites you visit across the internet for remarketing purposes, including cross-device remarketing. Google and other third parties will use cookies to tailor advertisements for website users based on their previous visit to our website. More information about cookies can be found in our Cookies Policy.

We do not have any control over the advertisements you see on other third party websites however you can request to opt out or customise these advertisements by using the Google Ads Preference Manager.

15. Recording Calls

We may record any telephone calls you make to us or we make to you or any other third party. This is for training, monitoring and quality purposes and to meet our legal and regulatory obligations. Some telephone calls may be observed by staff for training and development purposes.

We may keep a copy of the telephone calls for at least 6 years from the date the telephone call was made.

16. Contact Us

If you have any questions or queries about how we use your personal information, or if you are unhappy with how we handle your personal information and would like to make a complaint, you can contact us using the address or email below:

Data Protection Officer
Ocean Finance
Think Park
Mosley Road
Trafford Park
Manchester
M17 1FQ

Email: [email protected]

If you remain unhappy with how we have dealt with your complaint regarding how we handle your personal information, you have the right to lodge a complaint with the Information Commissioner’s Office. You can find their details on their website at https://ico.org.uk/

17. Updates to this Privacy Policy

We may make changes to this Privacy Policy from time to time and any changes will be published on our website. If we make any important or significant changes to the way we may collect and use your personal information we will endeavour to notify you of this change.