Privacy Policy

Last Updated: 16 August 2018

At Bas Digital Limited we’re committed to protecting and respecting your privacy. We know that you care about how your information is used and shared and we appreciate your trust in us to do that carefully and sensibly. This notice describes our privacy policy and forms part of our website terms and conditions (“Website Terms”).

Your application is being processed by Bas Digital Limited. Bas Digital Limited believes it is important to protect your Personal Data (as defined in the Data Protection Act 2018) and we are committed to giving you a personalised service that meets your needs in a way that also protects your privacy. This policy explains how we may collect Personal Data about you. It also explains some of the security measures we take to protect your Personal Data and tells you certain things we will do and not do. You should read this policy in conjunction with the Website Terms.

By accepting our Website Terms or by visiting (‘the Website) you are accepting and consenting to the practices described in this Privacy Policy.

Who are we?

Bas Digital Limited (registered number 2857244), whose registered office is at 20th Floor, Central Tower, Queens Road Central, Central, Hong Kong.

Registered under the Data Protection Act [2018] with the Information Commissioner’s Office: Registration Number: ZA539190.

Bas Digital Limited - FCA reference number: 826926 is an Introducer Authorised Representative for Nouveau Finance Limited - FCA registration number: 727348.

How do we collect information from you?

We collect Personal Data from you:

When you take a service or product from us.

When you contact us, or if you have replied to a communication from us.

A third party who sells your data.

What type of information is collected from you?

This includes:

1. contact details
2. date of birth
3. employment details
4. email details
5. IP addresses
6. bank details

What is our lawful basis for collecting this data and why do we need this?

In order for us to process your data we have to have a lawful basis to do so. We are relying on the following basis to do so:

(a) Consent: you have given clear consent for us to process your personal data for a specific purpose.

(f) Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests.

We have identified these on a lawful basis to assess whether we can, pass your details on to our panel of lenders for a loan, pass your details to a third party who may assist you with obtaining a loan or if we wish to continue to market to you with other specific products set out below.

How is your information used?

We and our third parties use your information so that:

1. We can identify you when you contact us.
2. We can identify accounts, services and products you may have from us.
3. We can offer you other products.
4. We can ensure we do not pass your details to the same third-party twice in a short period and so third parties can avoid unnecessary credit searches.
5. We can improve your account administration.
6. We undertake marketing analysis, credit strategy and customer profiling.
7. We can continue to market to you with relevant offers.
8. To help us prevent and detect fraud or loss

Do you record calls or emails?

No

Who has access to your information?

1. all our staff;
2. third parties including police or government agencies should they request it;
3. if any officials request it for legal proceedings;
4. credit brokers or affiliates – if we sell your data;
5. Lenders, if we sell your data;
6. if our company and all of its assets are bought by a third party your personal data will also be transferred to this third party;
7. if we need to pass on personal data to others who offer administration services, marketing information and customer services.

What type of third parties do you pass my data to?

When you select the box to share your information with selected third parties you agree to receive communications (including mail, email, telephone, fax, automated voice messaging, text/SMS or multimedia messages) the categories of products offered by those third parties are listed here:

Lenders including but not limited to:

1. unsecured lenders;
2. secured lenders;
3. short term lenders;
4. alternative lenders;
5. peer to peer lenders;
6. guarantor lenders;
7. car finance, logbook loan lenders;
8. debt management providers;
9. credit report information service providers; and
10. other credit brokers.

For a detailed list of these third parties you can write to us at customers@zipcash.co.uk

Do you sell data?

Yes.

Why do you sell data?

We are a licenced credit broker. That is our business and how we make our revenue. If you apply on one of our websites for a loan we will pass your details to one of our panels of lenders. You will be matched according to your requirements. We will be paid a fee for the introduction by the lender.

How safe is my data?

We carry out comprehensive due-diligence on each party that we work with to ensure your personal data is secure and that the communication you receive is relevant to your needs. Communication from the third party may be by email, SMS or telephone.

We will not disclose your Personal Data to any third party except in accordance with this Privacy Policy.

Can I refuse my data being sold?

Yes, you can. If you do not wish for your data to be sold, do not submit your application on our website. We are an authorised credit broker and the nature of our business is to sell your data which is how we generate revenue.

Can I change my mind about marketing?

If you consented to receiving marketing communication from us, there will be an opt-out on every correspondence you received. You can also change your mind at any time by emailing us at customers@zipcash.co.uk or by visiting any of our websites.

How can I update and access my information?

Please email us at customers@zipcash.co.uk

What security do you have to protect my data?

We have a very strict policy on protecting your Personal Data:

1. We make sure we do thorough checks on everyone we work with.
2. We use encrypted software.
3. We continually test our systems to see whether it can be penetrated by malicious software and outside third parties looking to steal data. Our regulators expect us to do this to ensure our systems are secure.
4. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information.

Do you use Cookies?

Yes

Why do you use Cookies?

Cookies cannot be used to identify you personally and are used to improve services for you, for example through:

1. letting you navigate between pages efficiently;
2. enabling a service to recognise your computer so you don’t have to give the same information during one task;
3. recognising that you have already given a username and password so you don’t need to enter it for every web page requested;
4. measuring how many people are using services, so they can be made easier to use and that there is enough capacity to ensure that they are fast.
5. See allaboutcookies.org or www.youronlinechoices.eu to learn more about cookies.

We use Google Analytics cookies to collect information about how visitors use our website and to help us ensure it is tailored to our customers’ needs and interests. These cookies only collect information in an anonymous form, including the number of website visitors and the pages visited. No personal information is collected or stored by Nouveau Finance. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout

Do you buy data?

Yes, we purchase data in a number of ways but always perform full due diligence on our partners to ensure that they Treat Consumers Fairly before we purchase. For further information email customers@zipcash.co.uk

Do we profile your information?

We do limited profiling so that we can match your specific needs to the loan product you require. Our panel of lenders may carry out their own profiling.

To find out what information we hold on you can write to us at customers@zipcash.co.uk

What age must I be?

18

Do we review our Privacy Policy?

Yes, we can update our privacy policy without letting you know. We will review this at a minimum annually.

How long do we store your data?

We store your data for up to three years after the last interaction.

What are my rights?

You have the following rights for your data:

The right to be informed

The right of access

The right to rectification

The right to erasure

The right to restrict processing

The right to data portability

The right to object

Rights in relation to automated decision making and profiling.

For further information in relation your rights visit www.ico.org.uk

Will you transfer my personal data to a country outside the European Economic Area?

Yes, we may transfer your personal data to a country outside of the European Economic Area (EEA) (including to our associated company in USA) and can assure you that any transfer made is necessary. The safety and security of your personal data is of the utmost importance to us and we have taken all necessary precautions to ensure your data is protected.

Who can I write to get more information about this Privacy Policy?

Bas Digital Limited
20th Floor, Central Tower, Queens Road Central, Central, Hong Kong.
ICO No. ZA539190

Complaints

If you would like to make a complaint about how we handle your information, or you have a complaint about anything mentioned in our Privacy Policy, please either write to us at Data Protection Officer, Bas Digital Limited, 20th Floor, Central Tower, Queens Road Central, Central, Hong Kong, or email us at customers@zipcash.co.uk

If you are not satisfied with how we handle your complaint, you can also complain to the Information Commissioner’s Office by contacting their helpline on 0303 123 1113.