10th February 2020
Checked and signed off
10th March 2020
Further, MB is registered with the Information Commissioner’s Office under the Act with a registration number of Z3334636 and will act as the data controller. MB is registered in England and Wales and has a Registered Office at The Old Bank, 247 Chapel Street, Salford, M3 5EP and Company Registration number of 07949139.
This Policy (together with our Terms & Conditions and any other documents referred to in it) sets out the basis on which any personal data we collect from those who register with us, or that is provided to us by Registrants from time to time, will be processed by us and the choices Registrants and Members have associated with that data. Please read the following carefully to understand our views and practices regarding the aforementioned personal data.
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in MB’s possession or likely to come into MB’s possession).
Usage Data is data collected automatically which is either generated by the use of the Service or from the Service infrastructure itself (for example, the pages visited during a session).
Cookies are small pieces of data stored on a User’s device.
Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed.
Data Processors (or Service Providers)
Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.
A Data Subject is any living individual who is the subject of Personal Data.
The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.
Information Collection & Use
We collect a number of different types of information for various purposes in order to provide and improve our Service to Members: -
- DATA TYPES COLLECTED
(1) Personal Data
- 1.1.1 this is information that you may provide by filling in online forms and registration forms on www.creditknowledge.co.uk (our "Site") and we may also ask you for additional information in the event you report a problem with our Site in order that we can verify your identity for security reasons and to resolve the problem you are reporting; for information, personally identifiable information may include but is not limited to:
First & Last Names
Postal Address including Post Code
Cookies & Usage Data
Your Personal Data may be used to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us. We use an identity verification service provided by TransUnion. You can find more information about how that service uses personal data in TransUnion’s Bureau Privacy Notice, which is available at: https://www.transunion.co.uk/legal-information/bureau-privacy-notice.
- 1.1.2 correspondence or a record of it should you contact Credit Knowledge or MB;
- 1.1.3 surveys that we may use for research purposes from time to time, which we may ask you to complete, although you do not have to respond to them and we may not contact all Members with every survey;
- 1.1.4 details of visits to our Site (including, but not limited to, communication data, location data, traffic data, weblogs and any other information as we may identify as useful, whether this is required for any of our own purposes or otherwise) and the resources that you access;
- 1.1.5 information to help verify your identity;
- 1.1.6 on occasion third parties with whom we work may ask you to provide documentation for the purpose of verifying your identity, such as bank statements or utility bills (and you should look at the relevant third party partners' Privacy Policies regarding this);
- 1.1.7. to confirm, if you post any comments, material or suggestions on our Site, this information will be collected and may be utilised by us
- 1.1 While using the Service, MB may ask Members to provide certain personally identifiable information that can be used to contact or identify you ("Personal Data").
- (2) Usage Data: IP Addresses & Cookies
- 2.1 MB reserves the right to collect information on how the Service is accessed and used ("Usage Data"). Such Usage Data may include information like your computer's Internet Protocol address (e.g. IP address), browser version, browser type, the Website pages that you visit(ed), the time and date of visit(s), any device identifiers, the time spent on each page(s) visited and any other diagnostic data;
- 2.2 Tracking & Cookies Data;
- 2.3 A "cookie" is a small electronic file that collects information when someone visits a website. A cookie can identify the pages that are being viewed; this can assist a Company to select the page(s) that a viewer sees based on previous visits or other data. Some cookies only exist whilst viewers are online although "persistent" cookies - which are not session-based - remain on the viewer's computer, so that he or she can be recognised as a previous visitor when he or she next visits a Site. This allows the Site owner to collect information about a viewer's browsing habits whilst on a Site and this can be useful in assisting in the monitoring of and improvement of services;
- 2.4 MB does not store sensitive information such as account numbers or passwords in "persistent" cookies and cookies in themselves, do not contain enough information to identify you. You will only acquire a personal identity in relation to your browsing habits after you have formally provided us with your personal data for the purposes outlined below;
- 2.5 In addition to using cookies, MB may also use web tools to collect information about browsing activities whilst on our Site. For this reason, any information that is obtained in this way is similar to the information supplied by cookies and it is used for the same purposes;
- 2.6 Any information that we acquire about you using cookies or web tools is subject to the same restrictions and conditions as any other information we collect about you and Credit Knowledge & MediaBlanket commit to observe these restrictions and conditions;
- 2.8 If you want to delete any cookies already stored on your computer or stop the cookies that keep track of your browsing patterns on the Site you can do so by deleting your existing cookies and/or altering your browser's privacy settings to block third party cookies (the process you follow will differ from browser to browser). If you would like more information on how to do this please visit http://www.allaboutcookies.org/. Please note that deleting our cookies or disabling our future cookies means that you may not be able to access certain areas or features of the Site and other Sites are likely to restrict access after any such change regarding their cookies.
Examples of Cookies we use:
Session Cookies are used to operate our Service;
Preference Cookies are used to remember any preferences you may have set and covering various settings;
Security Cookies are used for to provide additional site security;
Advertising Cookies may be used to serve you with advertisements for selected products that may be relevant to you and your interests
- 2.9 Use of Data
Credit Knowledge and MediaBlanket Ltd use the collected data for various purposes:
allowing any interactive features of our Service to function properly should you choose to make use of them
allowing for the provision of Customer Service activities
allowing for the provision and maintenance of our Service
allowing Credit Knowledge and MB to notify you about changes to our Service
allowing for the gathering of information to use in analysis so that we can improve our Service
allowing MB to monitor the usage of our Service
allowing MB to monitor and eradicate technical issues
allowing for the provision of general information, news and special product offers about various other services which we may offer from time to time that are similar to those that you have already purchased or registered an interest in unless you have advised us that you do not wish to receive such information.
- (3) Data Retention: Storage of Data
MediaBlanket Ltd also reserves the right to retain Usage Data for internal analysis purposes. Usage Data is generally retained for less time than other Personal Data, other than in circumstances when such data enables us to strengthen the Service’s security or where a legal obligation exists to retain such data for longer periods or to give added functionality to the Service.
- 3.1 All information provided to us is, as far as reasonably practicable, stored on our secure servers. Any financial information, such as credit or debit card numbers will be encrypted using SSL technology. MB asks that you do not to permit anyone to use your name or details in applications or registrations. MB employs industry standard security measures to ensure the security of all PCCI compliant data. Any data that is stored on MB's secure servers is treated as proprietary and confidential and is not available to the public. MB has an internal security policy based on restricted access, (using login and password limitations), with regards to the confidential nature of customer data allowing access only to those members of staff or related third parties who have a need to know such information for the purpose of effectively delivering MB services and any such users have been given training on their responsibilities therein. MB regularly assesses its data security practices to identify new security threats or opportunities to improve protection.
- 3.2 Unfortunately, it is widely accepted that the transmission of information via the internet is not a completely secure process. Although Credit Knowledge and MB will take all reasonable steps to protect your personal data, we cannot guarantee the security of your data as it is transmitted from you to our Site; any such transmission is at your own risk. Please see our Terms & Conditions concerning our liabilities in this regard.
- 3.3 Your information will be retained securely stored for a reasonable period or for as long as the law require
- (4) Use of Your Information
- 4.1 MB will make use of information held about you in the ways listed below:
- 4.1.1 to process and submit your request to relevant third party partners;
- 4.1.2 to assist such third party partners to verify your identity and, further, to provide you with a copy of your credit file, credit score and/or other credit reporting information;
- 4.1.3 to provide your Membership service;
- 4.1.4 to make sure that our Site is at all times displayed in the manner intended irrespective of device upon which it is being viewed;
- 4.1.5 to maintain the highest level of service;
- 4.1.6 in order to advise you of any alterations to the Service;
- 4.1.7 in order to display any comments you have submitted via a contact form or message board;
- 4.2 MB may use your data to provide information about products or services which we feel may be of interest to you, largely but not solely based on previous activity on the Site. Such contact may be via e-mail, post or text message and may relate to MediaBlanket, Credit Knowledge or other MediaBlanket brands, (including but not limited to 121money, Autodosh, Knowso, SupaFinance, SupaLoans, TangerineLoans and TheLoanTree; MB may use your data to provide information about products or services offered by trusted third parties which we feel may be of interest to you - for example, Lenders and Credit Card providers, although providers of other products or services may be marketed to you;
- 4.3 You can opt-out of such correspondence at any time by calling us on 0161 711 0420, emailing us at firstname.lastname@example.org or writing to us at MediaBlanket Ltd t/a Credit Knowledge, The Old Bank, 247 Chapel Street, Salford, M3 5EP;
- 4.4 Upon receipt of an opt-out request vis a vis our use of your data for marketing purposes, such request will be honoured after we have had reasonable time to process your request, (with our intention being that all requests are acted upon as swiftly as possible); MB reserves the right to take reasonable steps to authenticate your identity with respect to any such request or other enquiry in order to ensure that only valid requests are actioned;
- 4.5 Only in circumstances where we have received the appropriate consent may we also share your data with very selected third party partners who may contact you from time to time with offers concerning related and unrelated products and services;
- 4.6 MB commits that any information or statistics relating to our Site(s) that we disclose to internal or external parties will not identify you personally. It could be that we perform a statistical analysis of the behaviour of the users of a Site in order to measure interest in the various areas of said Site and so that advertisers are advised as to how many consumers have seen or "clicked" their advertising assets. This information, and any other general information about our users that we share with advertisers and other partners, will not disclose personal information about any particular visitor or Registrant;
- 4.7 Personal Information may be shared with third parties who perform services on MB’s behalf. It may be that third parties host our Website(s), provide email or text message sending services, operate amenities within our Site(s), provide customer research initiatives, provide the platforms for us to authorise and process your payments – this list is for the purposes of example and should not be considered as exhaustive. Any third parties that receive such information from us only have authority to use or disclose the information we supply to them to solely to the extent necessary to perform services on our behalf or comply with legal requirements. Any Personal Information shared with such third parties is protected. 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. 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 in relation to this information, can be found by visiting the website of Cifas, a fraud prevention service, at www.cifas.org.uk;
- 4.8 Please note that any valid opt-out request will only apply to the removal of consent for marketing purposes and this will not prevent MB or any relevant third party service providers from contacting you to provide account-related, billing-related or service-related information, (commonly known as transactional emails or SMS, to include password reset emails, for example).
- (5) Transfer of Data
Any and all information information held by Credit Knowledge and MediaBlanket Ltd, including Personal Data, may be transferred to and held on computers located outside of the EEA where the data protection laws may differ than those from within the EEA; all reasonable steps are taken to ensure that only those service providers which attest to maintain at least the same level of security standards as those within the EEA are accepted to provide such services to Credit Knowledge and MediaBlanket Ltd.
If you are located outside the United Kingdom and choose to provide information to us, please note that we may opt to transfer the entirety of the data, including all Personal Data, to the United Kingdom and process it there.
Personal Data held shall only be transferred to a country outside the EEA if there is adequate protection in that country.
- (6) Disclosure of Personal Information
Acquisition, Merger or Partial Sale
Law Enforcement Requirements
Under certain circumstances, MediaBlanket Ltd may be obliged to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
MediaBlanket Ltd may disclose your Personal Data in the good faith belief that such action is necessary to:
To comply with a legal obligation MB has
To prevent or investigate possible wrongdoing in connection with the Service
To protect MB against any legal liability it reasonably feels it is exposed to or may become exposed to
To protect and defend the rights or property of MB
To protect the personal safety of users of the Service or the public
Security Of Data
MB takes the security of User data very seriously but as mentioned before, no method of transmission of data is entirely secure. Unfortunately, as such, we cannot guarantee its security at all times but we do take all reasonable steps to ensure industry-standard levels of protection.
- 6.1.1 to prepare or send any communications to you, or to assist us in connection with any of our administrative or business functions, or in the provision of any of our services to you;
- 6.1.2 if MB or substantially all of its assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
- (7) Your Rights
MediaBlanket Ltd will always do our utmost to make our systems able to accept reasonable amendments, corrections and deletions of Member details within Member accounts or permit the change of consents given by Members from time to time.
It is always our intention to allow Members to update Personal Data directly within your account settings section but there may be elements which need to be changed by our staff and under these circumstances, please contact us to make the desired changes, (we reserve the right to confirm your identity before actioning any such request and if we cannot be reasonably satisfied that the request has been received from you, we reserve the right to refuse to make the change as requested; we also reserve the right to refuse to change any elements that would cause us to contravene any legal obligations we may have).
As detailed within data protection legislation, there are circumstances in which you have the right:
To access and receive a copy of the Personal Data that is held about you
To rectify any Personal Data held about you that is inaccurate
To request the deletion of Personal Data held about you
To request the portability of data you have provided to MediaBlanket Ltd
- 7.1 As with the contents of Clause 1.1.6, on occasion our Site may contain links to and from the websites of advertisers and affiliates with which we are partnering at that time. Where a visitor to our Site follows any such link, it is the visitor’s own responsibility to check the Privacy Policies provided on the relevant third party Sites and we do not accept any responsibility or liability for these policies or actions visitors take once on those Sites. Please check these policies before you submit any Personal Data to these Sites;
- 7.2 As referred to above, Section 7 of the Act gives you the right to view information held about you. In order to exercise your right to access the information held about you, please write to us at Credit Knowledge, MediaBlanket Ltd, The Old Bank, 247 Chapel Street, Salford, M3 5EP. Any such request for data access may incur a small statutory fee to meet the costs in providing you with details of the information we hold about you;
- 7.3 In order to enable us to ensure our Customer Services activities are at the necessary standard, we may record and monitor calls between us;
- 7.4 If you want to change, modify or update your member information you can do so by calling us on the number provided, (although we may request confirmation of the change in writing for our records), or email or write to us on the contact details listed above;
- 7.5 If you were introduced to us by a third party, they may require that we give them your contact details and sufficient information about you for their accounting and administration purposes and by submitting your details to us, you agree to this; any such passing of information will be limited to the bare minimum that is required;
- 7.6 Information about you and how you manage your account may be passed to the following:
- 7.6.1 as referred to in Clause 5 above, partners providing a service to us or acting as our agents on the understanding that they will keep the information confidential; if such partners are located outside of the EEA, we will make sure that they agree to apply the same levels of protection as we are required to apply to information held in the EEA and to use your information only for the purpose of providing the service to us;
- 7.6.2 as referred to in Clause 6, on the occasion of MediaBlanket Ltd being a party to an acquisition, an asset sale or a merger etc, then the other party may be entitled to view the business activities of MediaBlanket and this may include Personal Data;
- 7.6.3 also as referred to in Clause 6, where there is a legal obligation to do so, we will pass your details to law enforcement.
- 7.7 Otherwise we will keep information about you confidential.
- (8) Credit Reference & Fraud Prevention Agencies
- 8.1 It is your responsibility to ensure that all the information supplied to us is true and complete and by submitting information to us, you understand that we will use this information to verify your identity;
- 8.2 In order to fulfil their obligations in the provision of the Services, third party partners will make such checks as they deem necessary including but not limited to verifying your identity and you should review their policies to make yourself aware of the checks they may perform;
- 8.3 In the event that it is established that false or inaccurate information has been provided and fraud can be identified, details will be passed to fraud prevention agencies and this may negatively affect your credit score, amongst other effects;
- 8.4 These inaccuracies may cause law enforcement agencies to access and use this information, with the possibility that legal proceedings may follow;
- 8.5 This information may be used by MB and other authorised parties to prevent fraud and money laundering;
- 8.6 The information held by fraud prevention agencies may be accessed from time to time by MB and other authorised parties from overseas locations;
- 8.7 If you have given permission for your Personal Data to be used for other very specific purposes then it may be used for these reasons.
- (9) Service Providers
As referred to in clauses above, if we utilise the services of third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used then these third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
- (10) Analytics
As referred to in a number of clauses above, (most recently Clause 9), there may be a need to make use of third-party Service Providers to monitor and analyse the use of our Service; one example of such a need is: -
Google Analytics is a service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service; Google may choose to share this data with any of their other services; if you have any concerns about this, you may wish to review Google’s policies to see how they use the data gathered in the performance of these services when providing their own advertising and marketing services.
Please visit the Google Privacy & Terms webpage: http://www.google.com/intl/en/policies/privacy/ to review their policies.
- (11) Advertising
- (12) Behavioural Remarketing
MediaBlanket Ltd may advertise on third party websites after you visit our Site. Advertisements may be displayed to you based on the information gathered by cookies by MB or third parties. If social media is used in the provision of these advertisements, please visit the Privacy Policies of the individual social media sites.
- (13) External Links
- (14) Privacy Governing Children
It is expressly not MediaBlanket Ltd’s intention to make this Service available to anybody younger than eighteen years of age.
MB does not knowingly collect personally identifiable information from anyone under the age of eighteen and if we are made aware of any such occurrence, we will take all reasonable steps to immediately remove their details from our systems.