Privacy ``Protecting You``
About this policy
This policy provides an overview of how The Tupper Loan Company Limited will process any personal information we collect about you and how we will comply with data protection legislation and protect the rights of the individuals we deal with.
It sets out below:
- Who we are and who is responsible for your personal data
- What personal information we collect about you
- How we use your personal information
- Where we transfer your information to
- Who do we share personal information with
- Confidential Information
- Your rights under data protection legislation
- How to contact us
The Tupper Loan Company Limited (the “Company”) is a wholly owned Jersey business offering services to individuals and companies looking to obtain finance. It is not authorised or regulated by the Jersey Financial Services Commission but does comply with the general principles of regulation.
The Company is registered in Jersey with company number 113366, whose registered office is:
The Tupper Loan Company Limited,
Three Oaks House,
La Rue Milbraie,
The Company is responsible for your personal data and will ensure that it is handled in accordance with the Jersey Data Protection Act 2018 (“DPA”).
If you have any questions or comments or issues regarding how we handle your personal information, please contact us at:
Email Address: firstname.lastname@example.org
Postal Address: The Tupper Loan Company Limited, 2-6 Anley Street, St Helier, Jersey, JE2 3QE
Or contact the Information commissioner at https://oicjersey.org/
We may collect and process the following data about you (“your information”):
Information that you submit online via our website including (but not limited to) when you apply for a loan or register an interest with us;
Any correspondence you send to us which might include, for example, business plans and financial statements, proofs of ID and CVs;
Copies of any agreements you enter into with us; and
details of your visits to our website and the resources that you access (which may include, amongst other things; traffic data and communication data).
We may also collect your information from third parties, including the Company’s Finance Partners and Credit Reference Agencies to make a decision about products and services we can offer through our partners. Any credit reference check carried out will leave a footprint on your file which may be seen by other lenders. Your consent will be obtained before conducting a credit reference check.
When you submit an application for a loan through Tupper Loan Company, we will check our own records for information on;
a) any existing loan that you may have, the status of that loan and the information you provided at the time of that application; and
b) if you have one, your financial associates’ Start Up Loan, its status, and the information provided by them at the time of that application.
Searches at credit reference agencies (using one of our Finance Partners) for information on:
a) your personal accounts;
b) if you are making a joint application now or have ever done, we will check:
each individual’s personal accounts; and
any previously made applications, either in a sole or joint capacity.
c) if you are a director or partner in a small business, we may also check on your business accounts.
These searches may reveal the following relationships:
joint account(s); and/or
those that are financially linked to other individuals;
but we do not search individuals who are not party to the application.
We will also search at fraud prevention agencies for information held about you, any addresses at which you have lived and any information about your business (if you have one).
IF AND TO THE EXTENT THAT YOU PROVIDE INFORMATION ABOUT YOUR SPOUSE OR FINANCIAL ASSOCIATE AND/OR WE OBTAIN THEIR INFORMATION AS PART OF THIS PROCESS, YOU CONFIRM THAT YOU HAVE OBTAINED THEIR CONSENT TO PASS THEIR INFORMATION TO US AND FOR US TO PROCESS IT AS DESCRIBED IN THIS POLICY.
If you give us false or inaccurate information and we suspect or identify fraud we will record this and may also pass this information to fraud prevention agencies and other organisations involved in crime and fraud prevention.
We use the information we receive in the following ways:
To help us assess your ability to repay the loan you are seeking;
To ensure that our website’s content is presented as effectively as possible for you;
For our internal purposes, such as research and analysis, reporting, quality control, website performance, system administration and to evaluate use of our website, so that we can provide you with enhanced services;
To notify you about changes to our products and services;
To provide you with information, products or services that you request from us, or which we feel may interest you (provided of course that you agree);
To create reports to assist with future marketing;
For complaint handling purposes;
To carry out our obligations arising from any contracts with you or under the law;
To enable you to participate in interactive features of our website, when you choose to do so; and
To help us improve our products and services.
We will only use information you provide relating to ethnicity and disabilities for monitoring and equal opportunities purposes.
We will use the details you give us to provide information you ask for or to put you in contact with the relevant Finance Partner to progress your loan application. Finance Partners have an obligation to keep your data secure. All applicants will be provided with a copy of the Company’s privacy notice by their Delivery Partner. This privacy notice sets out the delivery partner’s obligations in handling applicant data, as well as the consent that must be gained from the applicant regarding use of their data.
We may use your information in case studies that we produce which will then be used for advertising and marketing purposes. We will obtain your consent to do this.
We will use the information we receive from credit reference agencies to:
• Assess your application for credit and/or;
• Check details on applications for credit and credit related or other facilities;
• Verify your identity and, the identity of your spouse, partner or other directors/partners but only if they are a party to your application;
• Undertake checks for the prevention and detection of crime, fraud and/or money laundering;
• Manage your personal and/or business account (if you have one) with us; and undertake periodic statistical analysis or testing to ensure the accuracy of existing and future products and services.
• We may use scoring methods to assess your application and to verify your identity.
Where you borrow or may borrow from us directly we will give details of your personal and/or business account (if you have one), including names and parties to the account and how you manage it/them to credit reference agencies.
We may make periodic searches of our own group records and at Credit Reference Agencies to manage your account, including whether to make credit available or to continue or extend existing credit. We may also check at fraud prevention agencies to prevent crime and money laundering.
We may use your information to provide you with marketing information that you request or that we feel may interest you by post, email and/or telephone (including SMS) as follows:
If you are an existing customer or have not made a purchase but have taken steps to do so by using the website or contacting us, we may contact you by post, email and/or telephone (including SMS) with information about products and services which are similar to those we previously provided to you, unless, at the time we collect your contact information, you have indicated that you do not want to receive marketing information; or
If you are a new customer, we may contact you by post, email and/or telephone (including SMS) only if you consent.
We will not pass your information to third parties for their marketing purposes, but if you have indicated that you wish to receive promotional offers, that we have negotiated on your behalf, with our preferred partners, then we may contact you by post, e-mail and/or telephone (including SMS) with such promotional offers.
If you do not want us to use your information for marketing purposes, please indicate your preference via the relevant boxes on any forms you submit when you are providing your contact information. You may also ask us at any time not to use your information for marketing purposes by contacting us via the following methods
Phone: 01534 721500
Post: The Tupper Loan Company Limited, 2-6 Anley Street, St Helier, Jersey, JE2 3QE.
We will not routinely transfer your information to, or store it, outside the island or to European Economic Area (“EEA”). If we wish to transfer your personal data outside the EEA to countries which do not have as developed data protection laws, we will ensure that it is adequately protected in accordance with principles of the Jersey data protection law 2018.
We will also share your information with our trusted Finance Partners so that they can consider your eligibility for support as well as lawfully authorised bodies such as the regulatory authorities, and police.
A Finance Partner is the organisation that provides successful loan recipients with the loan proceeds and appears as the lender on the Loan Agreement. Tupper Loan Company will confirm who the Finance Partner will be prior to the loan being created.
We may share your information with other organisations:
If we have to share your information to comply with legal or regulatory requirements, or if we have to enforce or apply our loan agreements or any other agreements or to protect our rights, property or our customers.
Please note, we are only permitted to protect information that is actually personal and or confidential in law and where, if we were to disclose it, we could be sued for breach of confidence. Information you give us which you may consider to be confidential, or may mark as confidential, may in fact not be confidential in law. However in respect of any information we receive from you that is truly confidential, we will take steps to ensure it remains confidential. Unauthorised disclosure or misuse of personal information by staff will lead to disciplinary action.
We review our policies and audit our procedures regularly.
We review this code and our other data protection policies annually to make sure they are appropriate and up to date. We also carry out regular audits to monitor our security policies and procedures and revise them if necessary.
You have the right to see a copy of the information we hold about you (with the exception of the assessment of your application), on payment of a statutory fee which is currently £10. Before we agree to this, you must provide us with sufficient evidence of your identity and sufficient details of the information you wish to see to enable us to locate it.
You have the right to be removed from our mailing lists, and those of our partner organisations. Instructions on how to stop further mailings can be found as above.
You have the right to correct any errors in information we hold about you, and to change or correct any details you have already given us. Please inform us about changes to your details so that we can keep our records accurate and up to date.
Subject to certain conditions you have the right to object to processing of your data and to the removal of your data from our records (right of erasure). Subject to a duly authorised request, and provided that it is lawful and appropriate to do so Tupper Loan Company will erase records held by the company and any 3rd parties over which Tupper Loan Company is the authorised controller.
We will respond within 40 days upon receipt of the request.
Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on the website, whichever is the earlier.
Your continued use of our website after that period expires means that you agree to be bound by the modified policy.
Our website is owned by The Tupper Loan Company Limited. For details about our registered office address please see clause 2 above.