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Privacy Policy


Last updated: 22 May 2018

At MMP Financial 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').

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

1.Who are we?
We are a financial services company who provide personal loans to customers in the UK. We operate under the following details:
MMP Financial Limited
Beechwood House
2-10 Windsor Road
Slough SL1 2EJ
FRN: 718863
ICO: Z3027708
2.How do we collect information from you?
We collect Personal Data from you:
a)When you take a service or product from us.
b)When you contact us, or if you have replied to a communication from us.
c)From Credit Reference and Fraud Prevention agencies.
d)A third party who sells your data.
3.What type of information is collected from you?
This includes:
a)contact details;
b)date of birth;
c)payment details;
d)bank details;
e)shopping preferences;
f)email details;
g)IP addresses;
h)Employment details.
4.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:
a)Consent: you have given clear consent for us to process your personal data for a specific purpose.
b)Contract: the processing is necessary for a contract (loan agreement) you have, or because you have asked us to take specific steps before entering into a contract (loan agreement).
c)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 provide you with a loan, continue to market to you or manage your account.
5.How is your information used?
We use your information so that:
a)We can identify you when you contact us.
b)We can identify accounts, services and products you may have from us.
c)We can offer you other products
d)We can prevent and detect fraud or loss.
e)We can check your information with fraud prevention agencies. If you give us false or inaccurate information and we suspect that there may be fraud we will record this.
f)We can improve your account administration.
g)We undertake marketing analysis and customer profiling.
h)We can continue to market to you with relevant offers.
We may also provide you with information regarding the following products and services:
a)Consumer credit that is not high-cost short-term credit.
b)Debt-counselling.
6.Do you record calls or emails?
Yes
7.Who has access to your information?
a)all our staff;
b)third parties including police or government agencies should they request it;
c)if any officials request it for legal proceedings;
d)debt purchasers – if we sell your debt;
e)credit brokers or affiliates – if we sell your data;
f)debt collectors if our loan remains unpaid;
g)solicitors if our loan remains unpaid and we pursue you in court;
h)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;
i)a third party if we need to pass on personal data to others so that we can collect debts that are owed, marketing information and customer services;
j)credit reference agencies; and
k)third parties who provided us with any outsourcing administrative services.
8.Which third parties specifically see my data?
These companies may process your data based on the above mentioned lawful basis:
Cross Canada Financial Inc., Financial Conduct Authority, Callcredit Information Group Limited, Soda Software Labs Limited, Credit Resource Solutions, BroadSoft, CashFlows, Secure Trading Limited, Modulr Finance Limited, Axcess Financial Europe Limited, Exact Target Inc., Solutions by Text, Txtlocal Ltd, SessionCam.
9.What data do the credit reference agencies use?
In order to process your application we will supply your personal information to credit reference agencies (CRAs) and they will give us information about you, such as about your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity.
We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations. Your data will also be linked to the data of your spouse, any joint applicants or other financial associates.
The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at www.callcredit.co.uk/crain
10.Do you sell data?
Yes
11.Why do you sell data?
  1. If we cannot provide you with a loan but our partner can.
  2. If our partner can provide you with another service.
We only pass your details with your full consent.
12.What types of companies might you sell my data to?
We may sell your data to the following types of companies who can offer you these type of products:
a)Credit brokers;
b)Affiliates
13.Can I refuse my data being sold?
Yes you can. If you do not consent for us to sell your details, they will not be sold.
14.Who do you sell data to?
We may sell your data to these companies:
  1. RU Media UK Limited
  2. Quint Group Limited
15.Can I change my mind about marketing?
There will be an opt-out option on every marketing communication you receive. You may also Contact Us at any time to update your marketing preferences.
16.How can I update and access my information?
You may Contact Us via any method to update your information.
17.What security do you have to protect my data?
We have a very strict policy on protecting your Personal Data:
a)We make sure we do thorough checks on everyone we work with.
b)We also ensure that you use a secure password to access your account and encourage you to sign off properly when using a shared computer.
c)We use encrypted software.
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.
18.Do we use Cookies?
Yes
19.Why do we use Cookies?
Cookies cannot be used to identify you personally and are used to improve services for you, for example through:
a)letting you navigate between pages efficiently;
b)enabling a service to recognise your computer so you don’t have to give the same information during one task;
c)recognising that you have already given a username and password so you don’t need to enter it for every web page requested;
d)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.
See allaboutcookies.org or www.youronlinechoices.eu to learn more about cookies.
20.Do you buy data?
Yes - We have a network of affiliates who we purchase data from. If you have been offered a loan or another service from us and this has come by way of purchasing these details we may have profiled or made an automatic decision on you to make those decisions. We will have sent you a direct link to this privacy policy explaining what we do or emailed you informing you that a decision has been made in this way.
21.Do we profile your information?
We profile your information so we can market products to you that match your interests.
22.Can I access my profile?
Yes – You can request the information we hold on you at any time. You can write to us at complaints@swiftsterling.co.uk and we will provide you with a copy. You can ask us to amend or erase this data.
23.Can I object to you profiling me?
Yes you can, by emailing us at complaints@swifsterling.co.uk
24.What age must I be?
18
25.How long do we store your data?
We store your data for the life of the contract and then up to six years after the last interaction.
26.Do we review our Privacy Policy?
Yes, we can update our privacy policy without letting you know.
27.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
28.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 Canada) 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.
29.Who can I write to get more information about this Privacy Policy?
MMP Financial Limited
Beechwood House
2-10 Windsor Road
Slough SL1 2EJ
complaints@swiftsterling.co.uk
ICO number: Z3027708