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Here at Think Money Limited, we understand that protecting your personal information is of utmost importance. This privacy policy explains how we collect, use and store your information and how we ensure your information is secure.

This privacy policy will apply to you if you provide your personal information to us, even if you decide not to go ahead with any product or service we offer. We provide a range of financial products and services, and your personal information may be used differently depending on the product or service requested by you. You can find this information easily within the 'How we use your personal information' section below.

If you’ve any questions about how we may use your personal information you can contact us.

If you click on a link that takes you to a third party website that is not ours, we will not be responsible for how they use your personal data. You should read their own privacy policy to understand how they may use your personal data.

Last update : 09/03/2018

The information we collect from you will depend on the product or service you apply for or the service that we provide to you. We will only collect information that we genuinely need, or where we're required to collect the information to enable us to perform our legal or contractual obligations necessary to provide you with the products or services, where we have a legitimate interest to do so, or where we have your permission.

This will likely include the collection of:

  • your personal details (e.g. name, date of birth);
  • address details;
  • contact details (e.g. phone number, email address);
  • special personal information* (e.g. health information);
  • financial information;
  • employment information;
  • information on how you use our website(s) and products and services.

Special Personal Information

* Data protection law defines some personal information as “sensitive data” or “special categories of data”. This includes information about physical or mental health, sexual life, religious beliefs, race or ethnic origin, political opinions, trade union membership or biometric data. This information may be necessary to collect, for example, when you apply for an insurance quote, or where it may help us to provide a better service to you. Where we need to collect and process this type of data about you, by providing this information to us you give your explicit consent for us and any other third party to process this sensitive data as set out in this privacy policy, unless we have a legal obligation to process this type of data.

Any personal information about you relating to criminal convictions or offences may only be used by us when authorised by law.

Information about other people

If you provide personal information about someone else, for example when a joint application is made, you must do so with the permission of the other person. If you enter into a service jointly with another person (for example, a joint current account), your personal information and any information about the service provided to you will be shared with the other person.

The personal information about the other person will be used in the ways as described in this privacy policy.

We can collect your information in a number of ways.

  • When you make an application or enquiry to us either by phone, email, our website, by a third party or by any other means;
  • Information received from a third party, for example when run checks with a third party, such as a credit reference agency or fraud prevention agency, or where you have previously agreed for your information to be shared with us, for example, if you have been introduced to us by another company.
  • When you participate in market research, competitions and promotions provided by us, or on our behalf.
  • By adding reviews or interacting with us using social media such as Twitter or Facebook etc.
  • When you use our online platforms, such as a mobile app or online account management.
  • When we may need to obtain up to date information about you to meet our legal or regulatory obligations.
  • Where you have given permission for your information to be provided to us.

We can only use your personal information where it falls into one or more of the following categories:

  • it is necessary to fulfil a contract we have with you;
  • you have provided your consent;
  • we have a legal or regulatory obligation to do so;
  • it is necessary to carry out a task which is in the public interest;
  • it is necessary to protect your vital interests; or
  • it is in our legitimate interest to do so and it is not against your rights.

How we will use your personal information will depend on the product or service being provided to you. You can select from the products below to see how your personal information will be used specifically to be able to provide you with the product or service. If you decide not to go ahead with any of the services we provide we will still process your personal information we have collected for the purposes set out in Other Purposes for Processing your Personal Information.

Current Account

When you open an account with us, you will have agreed to our terms and conditions, (these can be found on our website, or you can request a copy from us). These set out how we will provide the services to you. To help us to do this, we will be required, under these terms and conditions and therefore to fulfil our contract with you, to process your personal information, for example:

  • providing you with a thinkmoney Card;
  • sending you regular account statements;
  • keeping you updated about your account and
  • setting up and processing payments with third parties such as your utility providers or mortgage provider.

Further details on how we will use your personal information when you open an account, and under what basis we can use your personal information are set out below:

What personal data do we need to collect?

When you open an account we will need to collect the following categories of personal information:

  • Personal information – such as your name and date of birth so we can correctly identify you and carry out our required checks.
  • Contact details – so we can contact you and send you any relevant communications about your application or account.
  • Income and expenditure details – so that we can set up any regular payments.
  • Photo Identification – if this is required to enable us to open an account for you.

This is required to fulfil our contractual and legal obligations.

Who will the data be shared with?

We will share your personal information with credit reference agencies (CRAs) when you apply for an account to consider your application. We will do this as part of our contractual and legal obligations to check your identity; check your eligibility for an account, and as part of our fraud prevention procedures.

For further information on how CRAs may use your personal information you can view the Credit Reference Agency Information Notice here or from the three main CRAs – Callcredit; Equifax; and Experian.

The thinkmoney Card is issued by us and Mastercard are the scheme provider. We will share information about transactions and activity on your Card with Mastercard, which we’re required to under our contract with them.

We will need to share your information with other banks, retailers or other third parties to allow us to set up any Direct Debits, regular payments or deal with any issues that may arise to fulfil our contractual obligations with you.

Our regulators, such as the Financial Conduct Authority, the Information Commissioner's Office or any other regulatory body or authority may request certain information as part of supervising us. We have a legal or regulatory obligation to provide this.

How long will your data be stored for?

Whilst you continue to be our customer, we will keep a record of your personal data to ensure that we provide you with the best service possible and where we’re required to keep your personal information to meet our legal and regulatory obligations. This will normally be kept for at least six years, starting from the date when we are no longer providing you with a service. Telephone calls will be retained for at least six years from the date the call was made.

After this time, we will delete the information or anonymise the data so that it cannot be linked back to you.

Loans

We are a broker and are able to offer our customers a range of loan products, including the Flexi Loan, the Current Account Plus Credit Facility and personal loans through our preferred broker and panel network. To allow us to provide these services to you, we will be required to collect and process your personal information as set out below.

What personal data do we need to collect?

When you apply for a loan we will need to collect the following categories of personal information:

  • Personal information – such as your name and date of birth so we can correctly identify you and carry out our required checks.
  • Contact details – so we can contact you about your application or enquiry for the Flexi Loan or Current Account Plus Credit Facility. If you apply for a personal loan, the selected lender would contact you about your application or enquiry.
  • Property details – so that necessary property checks can be made.
  • Income and expenditure details – so that we can accurately work out what you can afford to pay.
  • Financial details – to arrange any payments to be set up.

This is required to fulfil our contractual and legal obligations.

Who will the data be shared with?

If you apply for the thinkmoney Flexi loan or Current Account Plus, the loan and credit facility is provided by Ideal Finance Limited. They are the lender and are part of our group of companies. We will share your personal information with Ideal Finance Ltd to enable them to assess any applications for credit to establish the appropriate type and level of credit to grant to you and to administer any loans they may provide. This is required to meet our’s and Ideal Finance Ltd’s legal and regulatory obligations for responsible lending.

We will share your personal information with credit reference agencies (CRAs) to search the information they hold about you. We will do this as part of our contractual and legal obligations. This can include information about your personal details; credit applications; public information, such as information on the electoral register; your financial situation and history and details of any joint credit commitments. The CRA will add details of any searches to your credit record which can be seen by other organisations that make searches, and they may use it to help make credit decisions about you, to prevent fraud and money laundering and to trace debtors.

If the application is joint, information about both applicants and the outcome of any searches will be shared.

For further information on how CRAs may use your personal information you can view the Credit Reference Agency Information Notice here or from the three main CRAs – Callcredit; Equifax; and Experian.

We can also help you find a personal loan through a preferred lender panel as well as panels operated by other brokers. Where you apply for this service, we will share your personal information with the panel and brokers to see if a loan may be available for you. The lender may run a credit search with CRAs to verify your identity and creditworthiness which may be seen by other lenders. If you go on to apply for a loan with a lender you should also read their privacy policy to see how they will use your personal information.

Our regulators, such as the Financial Conduct Authority, the Information Commissioner's Office or any other regulatory body or authority may request certain information as part of supervising us. We have a legal or regulatory obligation to provide this.

How long will your data be stored for?

Whilst you continue to be our customer, or once you have made an application or enquiry for a personal loan, we will keep a record of your personal data to ensure that we provide you with the best service possible and where we’re required to keep your personal information to meet our legal and regulatory obligations. This will normally be kept for at least six years, starting from the date when we are no longer providing you with a service or once you have submitted a loan application or enquiry through our website. Telephone calls will be retained for at least six years from the date the call was made.

After this time, we will delete the information or anonymise the data so that it cannot be linked back to you.

thinkmoney Credit Card

We work with Capital One plc to provide the thinkmoney Credit Card. You can apply for the thinkmoney Credit Card through our websites.

What personal data do we need to collect?

If you apply for a credit card we will need to collect the following categories of personal information:

  • Personal information – such as your name and date of birth so we can correctly identify you.
  • Contact details – so that we can contact you about your application or enquiry.
  • Income and expenditure details – so that we can accurately work out what you can afford to pay.
  • Financial details – to arrange for any payments to be set up or to validate your identity.

This is required to fulfil our contractual and legal obligations.

Who will the data be shared with?

If you apply for the thinkmoney Credit Card your personal information will be shared with Capital One who issue the Think Money Credit Card.

Before you apply for a thinkmoney Credit Card, if you agree we can share your personal data on behalf of Capital One with Credit Reference Agencies (CRAs) to carry out a QuickCheck to see the likelihood of whether your application would be accepted. This check would appear on your credit report but would only be visible to you. You can read the QuickCheck terms and conditions here.

Capital One will review the information provided to assess your application and decide whether they will be able to provide you with a thinkmoney Credit Card. If successful Capital One will then process your personal data for the purposes of providing and administering your Think Money Credit Card. You can view Capital One’s privacy policy here.

For further information on how CRAs may use your personal information you can view the Credit Reference Agency Information Notice here or from the three main CRAs – Callcredit; Equifax; and Experian.

Our regulators, such as the Financial Conduct Authority, the Information Commissioner's Office or any other regulatory body or authority may request certain information as part of supervising us. We have a legal or regulatory obligation to provide this.

How long will your data be stored for?

If you successfully apply for the thinkmoney Credit Card, we will keep a record of your personal data to ensure that we provide you with the best service possible and where we’re required to keep your personal information to meet our legal and regulatory obligations. This will normally be kept for at least 6 years, starting from the date when we are no longer providing you with a service. Telephone calls will be retained for at least 6 years from the date the call was made.

After this time, we will delete the information or anonymise the data so that it cannot be linked back to you.

Insurance

We work with Think Insure Limited who are an insurance broker and work with a panel of insurers for life insurance products. Think Insure have previously provided insurance brokerage services for home, motor and gadget insurance. If you have previously taken an insurance product through Think Insure your personal information will be processed as set out below.

For home and motor insurance products we currently work with Be Wiser Insurance Services Limited (Be Wiser) to introduce customers to their website to obtain insurance quotes. Be Wiser may share some of your information with us to allow us to provide you with any incentives which you may be eligible for, for example, if you were offered a voucher or other incentive if you took out a policy through Be Wiser.

What personal data do we need to collect?

For life insurance policies, or any other insurance policies previously provided by Think Insure the following categories of personal information are collected:

  • Personal information – such as your name and date of birth so we can correctly identify you.
  • Contact details – so that we can contact you about your quote or policy.
  • Health information and criminal convictions – this is necessary for the insurer to be able to provide an accurate quote.
  • Income and expenditure – so that we can accurately work out what you can afford to pay.
  • Financial details – to arrange for any payments to be set up or to validate your identity.

This is required to fulfil our contractual and legal obligations.

Who will the data be shared with?

To enable us to provide you with a quote and to fulfil our contact with you, we will share your personal information with insurers to be able to provide you with a quote and to administer the insurance policy. You can find the insurers who we work with on our website.

If you pay for your home or motor insurance premium on a monthly basis under a credit agreement with Ideal Finance Limited (who are also part of our Group of companies) your personal information will be shared with Ideal Finance to enable them to collect your payments and make any payment arrangements where required under the credit agreement.

Our regulators, such as the Financial Conduct Authority, the Information Commissioner's Office or any other regulatory body or authority may request certain information as part of supervising us. We have a legal or regulatory obligation to provide this.

How long will your data be stored for?

Whilst you continue to be our customer, we will keep a record of your personal data to ensure that we provide you with the best service possible and where we’re required to keep your personal information to meet our legal and regulatory obligations. This will normally be kept for at least 6 years, starting from the date when we are no longer providing you with a service. Telephone calls will be retained for at least 6 years from the date the call was made.

After this time, we will delete the information or anonymise the data so that it cannot be linked back to you.

Other Purposes for Processing your Personal Information

Websites and marketing

To help us better understand you and provide you with information about other products which may be suitable and relevant, we will use your personal data to create a profile of you and your circumstances. This allows us to more accurately provide services to you. For example, we may assess your income and expenditure to determine whether you would be able to successfully apply for a personal loan through us. We believe we have a legitimate interest to do this and that it is not against your rights. However, if you don’t want us to profile your personal information this way, to then better enable us to tailor any marketing communications to you, you can contact us to let us know that you wish for your personal data not to be used in this way.

Reviews and Market Research

Under our legitimate interests, where we have a copy of your personal information we may contact you to ask you to provide a review about the services you’ve received or where we are carrying out market research which may help us design future products and services or to help improve our current services. Although this information would really help us, you wouldn’t be required to provide us with this information unless you were happy to.

Legal or Regulatory Obligation

We will be required to process your personal information where we have a legal or regulatory obligation to do so, for example, to adhere to anti-money laundering regulations and our regulatory commitments set out by the Financial Conduct Authority.

Responding to complaints or enquiries

If you make an enquiry or complaint with us, we will use your personal information to investigate the complaint and deal with your enquiry. We have a legal and regulatory obligation to deal with your complaint appropriately.

Internal Analysis

As part of our legitimate interest to develop our business and our products we will use your personal information to assess our performance as a business and for statistical analysis. We will use as little personal information as we can to achieve this. We may also share this information with third parties who provide us with services and where we have a contractual obligation to do so.

An automated decision is one which we rely on a computer or system to assess the information you provide to us to make a decision about you. This may include:

  • assessing your eligibility for a product or service, for example a credit check for a credit card or loan application
  • detecting any fraudulent activity which may be taking place, or there is a risk that it could take place
  • checking identity and residency statuses

If we do make an automated decision about you, in some cases you have the right to ask that we do not make our final decision based solely on the automated decision, and you can also object to the automated decision and ask that someone reviews it. If you want to do this you'd need to contact us or use the contact information which will be provided to you once you’ve received the automated decision.

In addition to the companies, organisations and other third parties set out in Section 3; we may also share your personal information with the following organisations:

  • IT Service Providers who provide technology platforms or other IT services.
  • Banks and finance companies that process transactions such as Direct Debits or card transactions (where applicable).
  • Communication providers (e.g. telephone line providers and email and text service providers).
  • Printers who print the letters and information packs which we send to you.
  • Advertisers and social media companies such as Facebook, Google and Twitter for our social media accounts or where we can contact you using your social media account.
  • Third parties who may have introduced you to our services.

These companies help us to provide our services to you. We will have a contract in place with any provider who directly provides us with such services to ensure that they comply with their data protection obligations and ensure that they have appropriate security measures in place.

We may also share your personal information where we have your consent to do so or where we’re required to do so under a legal or regulatory obligation or court order, such as the police, local authorities or the courts.

The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud, money-laundering and terrorist financing and to verify your identity. If fraud is detected, you could be refused certain services, finance or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found by contacting us or email us at [email protected]

We use publicly available social media platforms to promote our services, to provide updates and to share any news and promotional updates. We may collect personal information from these social media platforms, for example, if you post a message on our Facebook page. By providing any of your information to us through these platforms, you should be aware that:

  • the social media web pages are publicly available, and you must not provide any personal or sensitive information on our pages that are accessible to the public, such as your account information. We may ask you for your account information via a private message to identify you and to service any request you make; and
  • each social media platform will process any personal information you provide through the platform and will be processed in accordance with their own privacy policy. The privacy policies will be available to view on each social media platform.

We will only share your personal information outside the European Economic Area (EEA), where we have your consent; to comply with a legal obligation; or where we work with a business partner to enable us to provide you with our services, and they process information outside of the EEA.

If we do share your information outside of the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA to ensure appropriate safeguards are in place. This may include putting in place a contract with the business partner that means they must protect the personal data to the same standards as the EEA (this may include defined model clauses), or only share the data to a business partner in a non-EEA country where the privacy laws provide the same protection as within the EEA or where they are part of a Privacy Shield.

More information on this can be found on the European Commission Justice Website.

We take the protection of personal information very seriously, and we will maintain appropriate measures to maintain the confidentiality, integrity and availability of the information you have provided. Such measures include:

  • Company security policies and standards.
  • Staff security awareness.
  • Role-based access controls to prevent unauthorised access to the information.
  • Encryption and anonymisation technology.
  • Anti-malware technologies.
  • Security monitoring.
  • Security testing.
  • Secure archiving and deletion.
  • Compliance with industry regulation and legislation.

To help us keep you up to date about the products and services that we provide to you and to ensure that you’re kept fully informed we may contact you by letter, telephone, email, text message, push notifications, social media or may send you messages by any online customer platforms or other electronic means.

If you don’t want to be contacted in a particular way, then you can request this at any time by contacting us, but if we are providing a service to you, we do need to be able to send you communications. This can often be due to a legal or regulatory requirement.

It is important that you keep us up to date when you change your contact details to ensure that we use your up to date contact information.

Access to your personal information

You have the right to request from us a copy of the personal information that we may hold about you. This is often called a “Data Subject Access Request”. You can request this information by contacting us as set out below. Up until 25th May 2018, we may charge you up to £10 to provide you with this information, but after this date, you can request this information for free.

Before providing this information to you or to another person or company where you have requested this personal information to be sent to, we may ask for proof of identity or ask sufficient questions to enable us to locate the information and ensure that we’re only providing it where you have given your agreement.

Right to have your personal information corrected

If the personal information we hold about you is incorrect, you have the right to request that we correct this.

Right to stop or limit the processing of the information we carry out

You may request that your personal information is deleted or that we stop processing the information if we’re no longer entitled to process it. There may be occasions where we are unable to delete the information due to our legal or regulatory obligations. We will, however, discuss this with you if you request for your information to be deleted.

Portability

In some cases, you may be able to request for your information to be provided to yourself or another company in a format that can be processed electronically by yourself or the other company. If you want to request this, you’ll need to contact us.

Whilst you continue to be our customer, we will keep a record of your personal information to ensure that we provide you with the best service possible and where we’re required to keep your personal information to meet our legal and regulatory obligations. This will normally be kept for at least six years, starting from the date when we are no longer providing you with a service. We will retain telephone calls for at least six years from the date the call was made.

After this time we will delete the information or anonymise the information so that it cannot be linked back to you.

If you have provided us with your consent or where we are legally entitled to do so, we may contact you to let you know about other offers, products and services that we provide which we think you may be interested or that may benefit you. We may do this through post, emails, text messages, telephone, push notifications, social media or other electronic means.

You can easily let us know at any time if you would no longer like to receive these messages. You can contact us using the details below, emailing us at [email protected] or unsubscribing using the link or information within the message.

When you visit our website or similar websites, Google may use our advertisements promoting our products and services which, may appear on other third-party websites you visit across the internet for remarketing purposes, including cross-device remarketing. Google and other third parties will use cookies to tailor advertisements for website users based on their previous visit to our website. More information about cookies can be found below.

We do not have any control over the advertisements you see on other third party websites however you can request to opt out or customise these advertisements by using the Google Ads Preferences Manager.

We will record any telephone calls you make to us, or we make to you or any other third party. This is for training, monitoring and quality purposes and to meet our legal and regulatory obligations. Some telephone calls may be observed by staff for training and development purposes.

We may keep a copy of the telephone calls for up to six years from the date the telephone call was made.

If you have any questions or queries about how we use your personal information you can contact us or our Data Protection Officer using the address or email below:

Data Protection Officer
Think Park
Mosley Road
Trafford Park
Manchester
M17 1FQ

Email: [email protected]

If you are not happy with how we process your personal information you should contact us. If you’re not happy with how we have dealt with your complaint, you have the right to make a complaint with the Information Commissioner’s Office. You can find their details on their website at https://ico.org.uk/.

Any updates to this privacy policy will be found on this page. If we make any important or significant changes to the way, we may collect and use your personal information we will endeavour to notify you of this change.

When using this website, some information may be collected automatically using 'cookies'. These are small text files that facilitate the processing of your information and enable us to analyse how the website is being used. Cookies can be temporary or permanent.

Temporary cookies form part of the security process while you are using the website; permanent cookies identify the link you used to find our website, check your browser so that we can make sure that our website and services work well with your computer and to help us monitor traffic on our website.

Why are cookies used?

They help visitors. Cookies allow sites to do things like provide personalised content and remember their log-in details and settings. You can turn them off - this won't stop a website from working, but it might mean it won't work as well as it could, or that you have to do the same thing more than once.

They help website owners. Cookies tell website owners things like what search engine a visitor used to find the website, how often they've visited it, how long they've spent on it, and so on.

We've set out below the cookies that we may use and those that are set by third parties on our website.

Cookie Name Purpose More Information
All Response Media _pk_(x) Visitor tracking Click here for more information about All Response Media cookies.
Amazon ad-(x) Display advertising and conversion tracking  
AOL API(x), C2,
ASCID, IDSYNC
Remarketing and conversion tracking  
AppNexus anj, uuid(x), sess Display advertising cookie Click here for more information about Outbrain cookies.
Bing Ads mui(x), _uet(x) Remarketing script and conversion tracking  
Cloud Flare _cfduid Security and performance script Click here for more information about Cloud Flare cookie.
DoubleClick Cookies _ide, _nid, _sid,
_dsid, _flc,
_aid, _taid
These are 3rd party cookies served by DoubleClick. They serve adverts to visitors based on the websites they've been to previously. Click here for more information about DoubleClick and how to disable this cookie.
Facebook fr Remarketing and conversion tracking Click here for more information about Facebook cookies.
Google Analytics _utm(x), _ga(x),
_gid, amp_token
These cookies are used to collect information about how visitors use our website. They keep track of when a visitor enters and leaves the website and any search engines and keywords that are used, including any personal and/or sensitive data. Click here for more information about Google Analytics cookies.
Hotjar _hj(x) These cookies are used to record anonymous videos about how visitors use our website. They keep track of how visitors engage with pages on our website. Click here for more information about Hotjar and how to disable this cookie.
Marin Software _msuuid, _msuuid_(x) Remarketing and conversion tracking  
Microsoft Azure ai_(x) Web performance monitoring  
Outbrain obuid, _ofcap_DOC1,
_utastes_1, _fcap_CAM4
Remarketing and conversion tracking Click here for more information about Outbrain cookies.
Quora m-b Remarketing and conversion tracking  
Taboola taboola_(x), t_(x),
JSESSIONID, DNT
Remarketing and conversion tracking Click here for more information about Taboola cookies.
Twitter guest_id,
personalization_id
Remarketing and conversion tracking  
Yahoo! B Remarketing and conversion tracking  
Our Cookies __sid Used for session tracking.  
Our Cookies __af Used to store internal system information.  
Our Cookies _culture Language code e.g. ‘en- GB’.  
Our Cookies HasMarketingConsent This allows the website to identify when a customer has started a journey in response to an e-mail.  
Our Cookies SourceId This allows the website to identify which source the customer has entered the website from.  
Session Variables ASP.NET_SessionId ASPESSIONID These cookies are used to keep all information about the visitor’s session of the website and are essential for the website to work. These expire when the browser is closed.  
Session Variables VISITOR_INFO1_LIVE This tracks a layout version that the YouTube applet will use when displayed on the website.  

Except for essential cookies, all cookies will expire after 10 years.

Disabling/Enabling Cookies

You have the ability to accept or decline cookies by modifying the settings on your browser and by Disabling/Enabling Cookies

You have the ability to accept or decline cookies by modifying the settings on your browser and by clicking on the ‘Disable cookies’ link below. Please remember though that disabling certain cookies may affect the functionality of our website.

If you are using Microsoft Windows Explorer:

  • Open 'Windows Explorer'.
  • Click on the 'Search' button on the tool bar.
  • Type 'cookie' into the search box for 'Folders and Files'.
  • Select 'My computer' in the 'Look In' box.
  • Click 'Search Now'.
  • Double click on the folders that are found.
  • 'Select' any cookie file.
  • Use the 'Delete' button on your keyboard.

If you are not using Microsoft Windows Explorer, then you should select 'cookies' in the 'Help' function for information on where to find your cookie folder.

We do not pass on or sell cookies to any other companies. Further information on the use of and managing cookies can be found at http://www.allaboutcookies.org.

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