CASHFOUNDRY LIMITED

PRIVACY POLICY

1 OVERVIEW

1.1 Cashfoundry Limited ("Cashfoundry" "we", "us" and "our") is a company registered in England and Wales under company registration number 07551380, having its registered office 28-32 Wellington Road St Johns Wood NW8 9SP
1.2 Cashfoundry is the holder of Consumer Credit Licence Number 644905 (category A, consumer credit and category C, credit brokerage) and provides short term personal loans and other financial services to consumers in the UK.
1.3 This Privacy Policy has been prepared by Cashfoundry to explain how we meet our obligations under the Data Protection Act 1998 (the "Act").  "You" and "your" means the customers who apply to use our services.
1.4 This Policy (together with our Website Terms and Conditions of Use sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Cashfoundry is registered with the Information Commissioner's Office with registration number Z2784366 and will act as Data Controller in accordance with the provisions of the Act.
PLEASE READ THE FOLLOWING CAREFULLY TO UNDERSTAND HOW WE ACQUIRE, PROCESS AND STORE YOUR PERSONAL DATA AND YOUR RIGHTS OF ACCESS.

2 INFORMATION WE MAY COLLECT FROM YOU

2.1 We may collect and process the following data about you:
2.1.1 Information that you may provide by filling in the forms on www.idosh.com (our "Site"). This includes information provided at the time when you complete the loan application form on our Site, or request further services.
2.1.2 Information obtained from you or from third parties, such as Credit reference agencies ("CRAs") (who may search the Electoral Register) and fraud prevention agencies ("FPAs") or other organisations when you apply for a loan or any other product or service or which you or they give to us at any other time.
2.1.3 Details of transactions you carry out through our Site and of the fulfilment of your loan(s) or other financial products we may offer.
2.1.4 Correspondence and records of all contact with you, including any discussions; please note that calls between us may be recorded and/or monitored.
2.1.5 Surveys that we use for research purposes, which we may ask you to complete, although you are under no obligation to respond.
2.1.6 Details of your visits to our Site and the resources that you access (this is partly acquired via our use of cookies; please refer to paragraph 7 below for further information about these).

2.1.7 Details of your IP address, operating system and browser type and other identifying information about the computer you use to access our site

2.1.8 Information from third parties in respect of you which may include your employer, a referee or a person residing or working from another country.

3 HOW WE USE YOUR INFORMATION

3.1 Cashfoundry collects and processes your data in order to provide you with access to short term personal loans and other financial services and to help top prevent fraud and money laundering.
3.2 We use information held about you in the following ways, namely to:
3.2.1 process your application;
3.2.2 assess your credit worthiness;
3.2.3 verify your identity and the identity of your spouse, partner or other directors/partners;
3.2.4 apply scoring methods to assess this application and to verify your identity;
3.2.5 manage your account and make collections;
3.2.6 develop, improve and update our products;
3.2.7 conduct statistical analysis;
3.2.8 notify you about changes to our service;
3.2.9 provide you with information about goods and services which may be of interest to you and we our affiliates or carefully selected partners may contact you about these by post, telephone, email, SMS or other reasonable method;
3.2.10 with your consent, permit selected third parties to provide you with information about goods and services which may be of interest to you (for example if we cannot provide you with the product or service you request and another party may be able to provide something similar) they may contact you by post, telephone, email, SMS or reasonable method.

3.2.11 we may sell or share your data with licensed credit brokers in the event that you apply on our site and we reasonably believe that a credit broker may be able to help you obtain a loan.
3.3 If you are making a joint application or tell us that you have a spouse or financial associate we will:
3.3.1 Link any individual identified as your financial associate, in our own records.
3.3.2 Take both your and their information into account in future applications by either or both of you.
3.3.3 Continue this linking until the account closes, or is changed to a sole account and one of you notifies us that you are no longer linked.
3.4 Your data may also be used for other purposes for which you give your specific permission or, in very limited circumstances, when required by law or where permitted under the terms of the Act.

4 STORING YOUR PERSONAL DATA

4.1 We will store and process your information securely as we deem appropriate, for example on our computers and servers for a reasonable period at least for the period required by law. .
4.2 All information you provide to us is, as far as reasonably practicable, is stored on our secure servers. Any financial information, such as credit/debit card numbers will be encrypted using specific security software. We ask you not to permit anyone to use your name.
4.3 In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. Further information is provided below under heading 5 'Security'.

5 SECURITY

5.1 When you enter our Site after the first occasion and want to check your account, we will check your identity by asking for your username and Passcodes. As long as the correct Passcodes are entered, we will assume that you are the person giving instructions and making transactions and you will be liable for those transactions.
5.2 You must never tell another individual your Passcode (nor other codes that protect access to your account) or write them down without disguising them.
5.3 You must tell us immediately if you suspect that someone else knows your Passcode that protects access to your account or can use Cashfoundry by impersonating you. Until you tell us:
(a) you will be responsible for any instruction which we receive and act on, even if it was not given by you; and
(b) we will not be responsible for any unauthorised access to confidential information about you on our website.
5.4 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorized access.
5.5 Our site may, from time to time, contain links to and from the websites of our advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

6 DISCLOSURE OF YOUR INFORMATION

6.1 We may disclose your personal information to third parties:
6.1.1 To process your loan application, or any of the services you have requested.
6.1.2 To prepare or send any communications to you.
6.1.3 To assist us in connection with any of our administrative or business functions, or in the provision of any of our services to you.
6.1.4 If Cashfoundry 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.
6.1.5 If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions of Use and other agreements; or to protect the rights, property, or safety of Cashfoundry, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
6.2 We may give information about you and how you manage your account to the following:
6.2.1 Law enforcement agencies in circumstances where we are required to do so by law;
6.2.2 Persons and legal entities which provide a service to us or are acting as our agents, on the understanding that they will keep the information confidential; and
6.2.3 CRAs and FPAs (see Clause 10 below).

7 AN EXPLANATION OF WHAT COOKIES ARE AND HOW WE USE THEM

7.1 A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps web applications to respond to you as an individual by gathering and remembering information about your preferences and which pages you visit.  Some cookies only exist whilst users are online but persistent cookies – which are not session-based – remain on the user's computer, so that he or she can be recognised as a previous visitor when he or she next visits our website. A cookie in no way gives us access to your computer or any information about you, other than the information you choose to share with us.
7.2 We use cookies to collect information about your computer, including, where available, your IP address, operating system and browser type, for system administration and to report information to our advertisers. The cookies we use, along with an explanation of what they do, is set out below
7.3 We do 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.
7.4 In addition to using cookies, we might also use web tools to collect information about your browsing activities whilst on our website. In this respect the information that is provided is similar to the information supplied by cookies, and we use it for the same purpose.
7.5 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.
7.6 Some of our advertisers may also use cookies or web tools that are set by other people such as advertising agencies, or the businesses to which the advertisements in question relate. We do not have access to any information that might be collected in this way, and, if you are concerned, you should contact the advertiser for more information.
7.7 The Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 requires that cookies can only be placed on a computer where the user has given their express consent. You can choose to accept or decline cookies when you first access our Site. We require you to indicate your choice via an automated "pop-up" box, which explains the cookies we use and what we use them for. Most web browsers automatically accept cookies, but you can also usually modify your browser setting to decline cookies if you prefer. If you decline to accept our use of cookies or set your web browser to decline their use, you will have only limited functionality in the use of our Site and we may decline any loan application

8 PROMOTIONAL AND MARKETING COMMUNICATIONS

8.1 By submitting Personal Data on our Website, you understand and agree that we, our affiliates and our carefully selected marketing partners may use your Personal Data, including the phone number, email address, or postal address you provide to us to contact you by post, telephone, email or SMS (Short Message Service) i.e., text message to assist you with your loan or to discuss other unspecified products and services that we, our affiliates or carefully selected marketing partners may provide

8.2 You may opt-out of receiving promotional emails and marketing communications from us, our affiliates and our carefully selected third parties by ticking the appropriate box on the loan application form on our Site, or at any time by responding to any of our email communications with "remove" in the subject line, by sending us an email to help@idosh.com or by contacting us at Cashfoundry Limited, 28-32 Wellington Road St Johns Wood, London, NW8 9SP. We reserve the right to take reasonable steps to authenticate your identity with respect to any such request or other enquiry.
8.3 If you opt-out of our use of your data for marketing purposes, we will honour such choice once we have had a reasonable opportunity to process your request.

9 YOUR RIGHTS

9.1 You have the right, under section 7 of the Act, to access information held about you. Your right of access can be exercised in accordance with the Act by writing to us at help@idosh.com or Cashfoundry Limited, 28-32 Wellington Road, St Johns Wood, London, NW8 9SP. Any access request may be subject to a small statutory fee to meet our costs in providing you with details of the information we hold about you.

10 CREDIT REFERENCE AND FRAUD PREVENTION

10.1 When you apply for a loan or other financial product we may offer, you confirm that all the information you have given is true and complete. You authorise us to check the following records about you and others:
(a) Our own;
(b) Those at CRAs; and
(c) Those at FPAs.
10.2 We will make checks such as assessing your loan application for credit worthiness in accordance with our responsible lending policy (see Clause 11 below). We may also make periodic searches at CRAs and FPAs to verify your identity and to manage your account with us.
10.3 Information on loan applications and details of your agreement(s) with us and any default or suspected fraud will be sent to CRAs and FPAs and will be recorded by them. This information may be supplied to other organisations by CRAs and FPAs and may be used and searched by us and other organisations in order to:
10.3.1 Consider applications for credit and credit related services such as insurance for you and any associated person;
10.3.2 Prevent or detect money laundering and fraud;
10.3.3 Trace debtors or recover debts;
10.3.4 Manage your accounts.
10.4 Records remain on file with CRAs and FPAs for 6 years after they are closed, whether settled by you or defaulted.
10.5 You have a right to be told which Credit Reference Agency we use and to obtain from the Agency a copy of your file. Some of the CRAs we use are listed below. For full written details of how your data may be used please contact the agencies below (they will charge you a small statutory fee).
10.5.1 Callcredit, Consumer Services Team, PO Box 491, Leeds, LS3 1WZ or call 0870 060l414 or visit www.callcredit.co.uk
10.5.2 Equifax PLC, Credit File Advice Centre, PO Box 3001, Bradford, BD1 5US or call 0870 010 0583 or visit www.myequifax.co.uk
10.5.3 Experian Consumer Help Service, PO Box 8000, Nottingham NG80 7WF or call 0870 241 6212 or visit www.experian.co.uk.
10.5.4 Teletrack UK Limited 6th Floor (South Tower), 26 Elmfield Road, Bromley, Kent, BR1 1WA or call 0845 0171 053 or visit www.teletrack.co.uk

11 YOUR CONSENT AND CHANGES TO OUR PRIVACY POLICY

By using our Site you consent to:

11.1 our collection and use of your personal information as described in this Policy. We reserve the right to amend this Policy at any time with or without notice. Any changes we may make to our Policy in the future will be posted on this page.  If you object to any of the potential uses of your information in the privacy policy we will not be able to process your application

11.2 our placing cookies of similar technologies on the machine you use to visit our site and/or you use to make an application

11.3 our sharing your data with carefully selected third parties who may contact you via means including but not limited to sms, email, direct mail and telephone about unspecified products and services

12 CONTACT

12.1 Questions, comments and requests regarding this Policy are welcomed at help@idosh.com or Cashfoundry Limited, 28-32 Wellington Road, St Johns Wood, London, NW8 9SP.
12.2 If you have any concerns about the information we hold you should contact the Data Protection Officer at Cashfoundry stating what you think the problem is and you will get a response within seven working days. If you still feel dissatisfied, you can appeal to the Managing Director of Cashfoundry or you can contact the Information Commissioner's Office by writing to the Customer Services Team, Wycliffe House, Water Lane, Wilmslow SK9 5AF; or by calling 0303 123 1113.