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Privacy Policy


Last updated: 17122018

At MMP Financial Limited, trading as Swift Sterling, 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 through a number of brands which we explain more about below.
Our details are as follows:
MMP Financial Limited
Beechwood House
2-10 Windsor Road
Slough SL1 2EJ
We are authorised and regulated by the Financial Conduct Authority under Firm Reference Number 718863. We are registered with the Information Commissioner’s Office under reference Z3027708.
We operate through a number of brands and this is the Privacy Policy of MMP Financial Limited and all its brands which together is what we mean by ‘we’ throughout this Privacy Policy. Our brands are:
Swift Sterling
My Money Partner
2. Who do we collect information from?
a) Users of our website.
b) Individuals who open an account with us.
c) Individuals who apply for a loan with us.
d) Individuals who currently have a loan with us.
e) Individuals who have previously taken out a loan with us.
f) Credit Reference and Fraud Prevention Agencies.
g) Authorised third parties from whom we may purchase leads and other data.
3. 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 when processing your application.
d) When we purchase your data from an authorised third party.
4. What type of information is collected from you?
This includes:
a) Contact details, such as email address and telephone numbers;
b) Your name and date of birth;
c) Home status, number of dependents;
d) Financial outgoings;
e) Income;
f) Bank details, card details;
g) Information obtained as a result of searches at credit reference agencies and fraud prevention agencies;
h) Marketing preferences;
i) IP addresses;
j) Employment status and employer;
k) Telephone recordings;
l) Emails;
m) Information concerning the loans you currently have or previously have had with us;
n) Information gathered by our use of cookies. More information can be found about cookies in our Cookies Policy;
o) Special Category (or sensitive) data such as:
a. Details of your current or former physical or mental health or where you receive disability payments; and:
b. Information relating to criminal convictions, including offences and alleged offences and any court sentences or criminal convictions.
5. 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 lawful bases in order to process your data:
a) Consent: you have given clear, explicit 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.
d) Legal or Regulatory: we have legal and regulatory obligations, such as our responsibilities to the Financial Conduct Authority, to comply with.
6. 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 where we have your consent to do so.
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 and our account administration.
g) We undertake marketing analysis and customer profiling.
h) We can continue to market to you with relevant offers where we have your consent to do so.
i) 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.
7. Do you record calls?
Yes. We record calls for Training and Quality Assurance. We keep these calls for up to six years after which the recordings are permanently deleted.
8. Who has access to your information?
a) All appropriate staff, i.e. all staff who need to access customer information as part of our operations;
b) Official, regulatory, government and police bodies such as the Financial Conduct Authority, Trading Standards and the police where required;
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) A third party who buys our company all of its assets, to whom your personal data would need to be transferred;
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 provide us with any outsourcing administrative services.
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.

This data will tend to be provided to us as systems data rather than specific, narrative reports. If you want to get your credit report then you can always get this, free of charge, direct from the credit reference agency concerned.

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, but only with your consent as we explain below.
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 an alternative financial product.
We only pass on 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 services:
a) Credit brokers who may provide you with loan or alternative financial offers; and
b) Affiliates who may provide you with loan or alternative financial offers.
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. Can I change my mind about marketing?
Yes. You first have the choice as to whether to opt in to marketing or not. If you have opted in though, there will be an opt-out option on every marketing communication you receive from us. You may also Contact Us at any time to update your marketing preferences.
15. 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.
The right to lodge a complaint with the ICO
You have a right to complain to the Information Commissioner's Office (ICO) if you believe that any use of your personal data by us is in breach of applicable data protection laws and regulations.
Details of how to make a complaint to the ICO are here: https://ico.org.uk/make-a-complaint/
For further information in relation your rights visit www.ico.org.uk.
16. How can I update and access my information?
To exercise your right of access (or any of the rights listed above) you may submit a subject access request (SAR) or just use any of the contact methods listed here.
We will respond to your request within one month and may contact you during this time to clarify your request if necessary. For manifestly complex requests we may seek an extension to this time period and possibly charge a fee.
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 and appropriate 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 delete or anonymise any personal information that is no longer required.
d) We use a range of organisational and technical security measures to protect your information including safeguards such as firewalls and data encryption.
e) We enforce appropriate physical access controls to our buildings, and we only authorise access to our buildings and files to those employees who require it to fulfill their job responsibilities.
f) When you share personal data with us through our website, that information is protected and our security systems meet or exceed industry standards.
g) 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 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.
19. Do we profile your information?
We profile your information so we can market products to you that match your interests where we have your consent to do so.
20. What age must I be?
18
21. 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.
22. Do we review our Privacy Policy?
Yes, we can update our privacy policy from time to time - notifications of updates will generally be posted on our homepage.
23. Will you transfer my personal data to a country outside the EU?
Yes, we may transfer your personal data to a country outside of the EU (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.
24. Who can I write/email to get more information about this Privacy Policy?
MMP Financial Limited
Beechwood House
2-10 Windsor Road
Slough SL1 2EJ
info@mmpfinancial.com
ICO number: Z3027708