We will collect personal information like your name, address and date of birth when you apply for, or use any of our products or services. We will also collect data from your use of our website and app.The type of information that we collect from you will depend on your relationship with us:
• Information requested from you when you make an application for one of our products or services(including, but not limited to name, postal address, telephone number, email address, date of birth) or at any time about your personal and financial circumstances or which we gather about you from the way you use and manage any account which we open for you.
• Details of any transactions (including any purchases of goods or services and other payments to and from your account) such as the amount, date and currency of a purchase and the supplier category (such as petrol station, supermarket or medical services).
• We will keep details and records of when you contact us and we contact you, like calls, emails, text messages, social media messages or other communications.
• User interactions and log data when you use our website(s) and app and click on our adverts on other websites (see information on cookies on our website)• Mobile device specific data.
• Information we receive about you from third parties, such as credit reference or fraud protection agencies.
• Information that is publicly available.
• Information from social media sites.
• Information requested from you when you register for the Tandem app including, but not limited to external security details for your linked accounts from the sites of external providers active on the Tandem App,
• Financial details (balances and transactions) of your linked accounts from external providers active on the Tandem App.
• Information requested from you which is required to complete a switching process via the Tandem App Please note that your external security details will be stored on a third party secure server and not on your mobile phone. Your external security details will be encrypted when stored and encrypted when data is transmitted – we will never see or have access to your external security details.
We collect information from you:
• when you apply for our products and services via our websites or our app
• when you talk to us on the phone, over email, by letter, via chat or social media
• when you make transactions using our products and services
• when you connect to our products and services using devices, such as computers and mobile phones, using cookies and other internet tracking software
Data protection law says that we are allowed to use personal information only if we have a proper reason to do so. We’ll process your personal data on the following legal basis and for the following purposes:
• As necessary to perform our contract with you for the relevant account, product or service:
• To take steps at your request before entering into the contract;
• To decide whether to enter into it, and, if you are applying for credit, the level of credit to offer you (including automated decision making relating to this);
• To manage and perform that contract;
• To complete a supplier switch that you have requested;
• To keep our records up to date;
• To trace your whereabouts to contact you about your account and recovering money thati s owed to us; and
• To analyse your balances and transactions of your linked accounts to identify opportunities to save.
As necessary for our own legitimate interests, that is when we have a business or commercial reason to use your information, for example:
• For good governance, accounting and managing and auditing our business operations;
• To keep our records up to date;
• Working out which of our products and services may be of interest to you;
• To search at credit reference agencies if you apply for credit;
• To monitor emails, calls other communications and activities on your account;
• For market research, analysis and developing statistics; and
• To send you marketing communications (including automated decision making relating to this).
• As necessary to comply with a legal obligation, for example:
• To comply with our legal and regulatory requirements and related disclosures e.g. where we have specific security obligations, such as two factor authentication, we will process certain of your personal data, in order to authenticate your transaction.
• To establish and defend our legal rights;
• For activities relating to the prevention, detection and investigation of crime;
• To verify your identity, make credit, fraud prevention and anti-money laundering checks;
• To monitor emails, calls and other communications and activities on your account.
• Based on your consent, for example:
• When we process any special categories of personal data about you at your request (e.g.information concerning your health);
• To send you marketing communications where we’ve asked for your consent to do so. You’re free to withdraw your consent at any time, however this will mean that we will not be able to do certain things for you.
We will use the personal information we hold about you, and data from the technology/devices you use to access your account(s) to:
• Provide, manage and develop our products and services
• Understand your preferences and advise you about our other products and services
• Undertake market research, transactional analysis, statistical analysis and system testing
• Update our records
• Recover debt
• Confirm your identity and location
• Assess whether you can afford the credit you’ve applied for
• Prevent and investigate fraud, money laundering and other crimes If we believe that you have tax obligations in another country, we may disclose personal information of yours with those tax authorities, or with HM Revenue and Customs, who may share the information with the other tax authorities. We may search, use and share the records held by domestic and international credit reference agencies and fraud prevention agencies, as well as our own internal records to:
• Confirm your identity and prevent fraud or money laundering
• Check your credit history and income details for affordability
• Check details on applications for credit and credit related to other facilities
The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies and may result in others refusing to provide services, financing or employment to you. 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 visiting Cifas and National Hunter. If you have any questions, or wish to find out more about the fraud prevention agencies we use, please call our customer services number on: 020 3370 0970.
Credit reference agencies keep a record of all searches, including those used to confirm your identity. Credit reference agencies also keep a record of whether or not your application is successful and whether you’ve missed any payments. Missing payments can negatively impact your credit rating so it’s best to call us on 0203 370 0970 before you do – we may be able to help you sort something out. We’ll inform the credit reference agency if you miss or are late on any payments. The agency may then make your personal information available to other organisations so that they can make a decision about you or a joint account holder you may have an account with. For joint applications, we’ll collaborate with our credit reference agencies to carry out joint searches. This will create a financial link between the applicants, which will be taken into consideration during any future searches on you or the other applicant. The financial link can only be removed successfully if you file for a ‘disassociation’ with the credit rating agency. We will make decisions to offer you credit and the level of credit to offer you based on automated processing, including profiling. If you do not agree with the automated decision you have the right to ask us to review the decision. If you want to understand more about a credit decision or to have a credit decision reviewed please call us on 0203 370 0970. For more information on how credit reference agencies work and to see their information notices please click on the links: Experian Equifax Transunion
• Third parties acting on our behalf, including our service providers and agents who help us manage your products and services, for example our payment, aggregation and switching partners;
• Fraud prevention agencies;
• Credit referencing agencies to check your credit rating;
• Know your Customer (KYC) and cyber security providers;
• Relevant government bodies, authorities and regulatory bodies in order to comply with our regulatory and reporting obligations;
• IT providers/hosted IT solution providers to enable us to provide our products and services to you;
• Debt collection agencies in the event we need to collect arrears from you;
• Other service providers via a shared, secured database for income verification and affordability checks and to manage/collect arrears;
• Our professional advisors (lawyers, accountants and consultants);
• Any other parties connected with your account e.g. guarantors and joint account holders;
• Market research companies to assist us in improving our product or service delivery;
• Any third party who is restructuring, selling or acquiring our assets, as long as that party uses the personal information in accordance with the terms of any agreements between you and us;
• If you have cards linked to your account, we’ll share transaction details with MasterCard, who provide our cards. They may transfer this information overseas to deal with transactions, resolve disputes and/or for statistical purposes.
• Anyone else where we have your consent or where it is required by law. We will make sure that anyone acting on our behalf only uses your personal information in line with our instructions and that they keep the data safe. We won’t share or give your personal information to external companies for their own marketing purposes.
We may also use your personal information to provide you with information about products or services which may be of interest to you where you have provided your consent for us to do so. We are committed to only sending you marketing communications that you have clearly expressed an interest in receiving. If you wish to unsubscribe from emails sent by us, you may do so at any time by clicking on the “unsubscribe” link that appears in all emails. Otherwise you can always contact us at firstname.lastname@example.org or on 0203 370 0970 to update your contact preferences.
Your personal data may be converted into statistical or aggregated data which cannot be used to identify you, then used to produce statistical research and reports. This aggregated data may be shared and used in all the ways described above.
• To maintain records according to laws and regulations that apply to us
• To show that we treated you fairly
• To respond to any questions or complaints
We may keep your data for longer than 7 years if we cannot delete it for legal, regulatory or technical reasons. Fraud prevention agencies can hold your personal data for different periods of time and if you are considered to pose a fraud or money laundering risk, your data can be held for up to 6 years.
You have certain rights under applicable data protection law, these rights are:
• The right to be informed about our processing of your personal data
• The right to request access to your personal data and information about how we process it
• The right to have your personal data corrected if it is inaccurate and to have incomplete personal data completed (the “right to rectification”)
• The right to have your personal data deleted (the “right to be forgotten”)
• The right to restrict processing of your personal data
• The right to move, copy or transfer your personal data (“data portability”)
• The right to object to the processing of your personal data
• Rights in relation to automated decision making including profiling
You can find out more information about your rights at the Information Commissioner’s website: www.ico.org.uk If you choose not to give us the personal information that we request either during an application process or during the life of an account or product, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform the services needed to manage your accounts/provide your chosen products and services. It could mean that we have to cancel a product or service you have with us. Please let us know if you are unhappy with how we have used your personal information. You can contact us at email@example.com or on 0203 370 0970. You also have the right to complain to the Information Commissioner’s Office who can investigate our compliance with data protection law. Find out how at www.ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
We will use reasonable endeavours to ensure that your personal information is accurate. In order to assist us with this, please notify us of any changes to the personal information that you have provided to us by updating your details on the Tandem App or by contacting us at firstname.lastname@example.org or calling us on 0203 370 0970.13.
We are required to employ adequate technical and organisational security measures to protect your personal information from any loss, destruction, damage or unlawful disclosure. However, please remember that no transmission over the Tandem App or the Tandem Website can ever be guaranteed as secure. Consequently, please note that we cannot guarantee the security of any personal information (including external security details) which you transfer via the Tandem App or the TandemWebsites.
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