Privacy Notice

At Nubnk Ltd trading as Offa, protecting your data is very important to us. We act as a data controller as defined under data privacy legislation when you provide us with your personal information (or your personal information is provided to us by someone authorised to make an application on your behalf). We will use your information to open and administer your account, for fraud prevention and detection, marketing (including promotion of products and services) and market research, to fulfil regulatory requirements and general business purposes.

The legal bases on which we process this data are:

• that it is necessary to fulfil our contract with you
• that it is necessary to comply with our legal obligations
• where you have provided us with consent for the processing and/or
• that it is in our legitimate business interests (in relation to the purposes stated above)

We may pass your personal information to: 

• anyone you appoint to administer or operate your account 
• regulatory bodies 
• our external auditors 
• any individual/organisation that we contract or employ to provide goods or services to us 
• any other person or organisation where you have given consent or if the law, public duty or our legitimate interests requires us to do so 

Your data will be kept while you are a customer and held for a minimum of six years after your relationship (as a customer) has ceased. You can always let us know if information we hold about you has changed, so we can update it.

Please make sure you provide us with certain information when requested as if you don’t, we may not be able to perform the contract we have entered into with you (such as, to provide you with products or services). In this case, we may have to cancel a product or service you have with us.

If you are making an application on behalf of another person, they must have authorised you to act on their behalf. This means you are allowed to provide their personal information with consent for us to use it, as described above. A copy of this privacy statement will be emailed to all applicants where an email address is provided.

We may make any enquiry relating to you that is considered necessary to confirm the accuracy of the information provided by you. This may include:

• a search of internal records 
• sharing your information with fraud prevention agencies and checking their records for similar applications made by you to other organisations 
• a search of the files of credit reference agencies 

In certain cases, the above checks may be used to automatically open your account without human intervention. We will never automatically refuse an application.

Credit reference agencies may check the details supplied against any particulars on any databases (public or otherwise) to which they have access. They may also use the details in the future to assist other companies for verification purposes. A record of the search will be retained. By proceeding with this application, you are agreeing to a search being undertaken in this way. We collect and use this personal data to administer your product and comply with our legal and regulatory obligations. We also process the personal data, where permitted by law for business analysis, fraud and crime prevention and to improve our services. These may involve disclosing your data to third parties such as HM Revenue & Customs (“HMRC”), fraud prevention agencies, our regulators, our legal advisers and our insurers. In the event of company reorganisation, merger, or buy out, it may be disclosed to a different group company. We may also obtain personal data from third parties. For example, we may use third parties to verify your identity or the source of your wealth. We may, at our discretion, make enquiries regarding your, or other persons, immigration status to the Home Office, validation of information supplied within the application process to HMRC under the HMRC Verification Scheme, any past/present employer, accountant, financier or bank in order to assess whether to accept your application and also at periodic stages during the term of your product.

The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money laundering 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 https://www.cifas.org.uk/fpn

Please note that credit reference agencies will keep a record of each search. This could affect your ability to get credit elsewhere within a short period of time. Details about this application (whether or not it goes ahead) will be recorded at the credit reference agencies.

A financial link between joint applicants or between you and any named partner or spouse will be created at the credit reference agencies. This will link your financial records, where each will be taken into account in all future applications by either or both of you. If you already have a financial association, your application will be assessed on this basis. This situation will continue until one of you successfully files for a ‘disassociation’ at the relevant credit reference agencies.

We will pass details about you and how you manage your account (if your application is successful) to credit reference agencies including recording if payments are not made in full and on time.

We may use automated methods to credit score your application. In certain cases the above checks may allow us to make an automated decision on your application, however, you can always contact us to arrange a manual review of your application on 0121 667 7291. However, additional information may be available on request would be helpful and could be considered as compliant but would not be best practice.

We may also make periodic searches at credit reference and fraud prevention agencies to help manage your account with us.

We may release any information relating to this application or the finance agreement to:

• any person consenting to the finance agreement
• the legal adviser acting on the finance agreement
• the financial adviser
• and any company responsible for these parties

We may disclose the information to insurers, reinsurers and their respective advisers, associate companies, agents and service providers including solicitors and valuers acting for us, debt recovery agents, letting agents, market research agencies and providers of information technology, for any purpose relating to any insurance we may arrange.

We may also pass any information or documentation relating to this finance agreement account (and any additional finance) to any guarantors while they remain liable for their guarantees.

If you have made a joint application, you confirm that you are entitled to disclose information about your joint applicant and anyone referred to by you; and authorise us to search, link or record information at Credit Reference Agencies and fraud prevention agencies about you and anyone referred to by you in the application. If you provide personal data about another person to us, you should provide them with this information concerning the processing of their personal data.

It is important that the personal information we hold about you is accurate and up to date. Please keep us informed if your personal information changes so that our records can be updated. We cannot be held responsible for any errors in your personal information in this regard unless you have notified us of the relevant change.

Data protection law grants you a number of specific rights in respect of your data in addition to the broad and general right to have your data protected. We have set out some information in respect of each of those specific rights, below:

• Right to be informed about how your personal information will be processed. This enables you to receive information about how we use your personal information. We have set this information out in this policy. 
• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information (commonly known as the “right to be forgotten”). This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes and to withdraw any consent that you have provided for processing.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.
• Not to be subject to a decision solely based on automated processing. We have highlighted in the ‘For our customers’ section above where automated decisions may be made in relation to your application.   If we ever make a decision about you automatically by a computer or an algorithm without human intervention you can ask us to have that decision reviewed by a human. 

You can also obtain your personal information held by credit reference and fraud prevention agencies.

If you want to exercise any of the rights set out above, please contact us using the contact details set out below.

For further information about how to exercise any of these rights please call our Customer Contact
Centre, or email our Data Protection Officer directly at www.offa.co.uk.

If you are unhappy about how your personal information has been used, please refer to our complaints policy. You also have a right to complain to the Information Commissioner’s Office which regulates the processing of personal information. For more information visit ico.org.uk.

Offa
Corner Oak,
1 Homer Road,
Solihull,
B91 3QG

Telephone: 0121 667 7291

Email: compliance@offa.co.uk 

Personal information means any information relating to an individual who can be directly or indirectly identified by reference to the information. Individuals are referred to as data subjects under data privacy legislation. A wide range of information constitutes personal data including names, contact information, identification numbers such as National Insurance numbers, financial information, employment details, and online identifiers often referred to as ‘cookies’ for example. This applies to both digital and paper[1]based information included within filing systems, or which is intended to be placed within a filing system.

The processing of personal information means any interaction with the information including viewing, collecting, sharing, storing, transferring or analysing it for instance. This can be by both a Data Controller, or a Data Processor.

The use of your personal information by third parties

When a third party processes your personal data on our behalf, we ensure that they follow our instructions to process and protect your personal data. Third parties are required to sign agreements in which they commit themselves to safeguard your personal data, agree to only use the data to provide services to us specifically outlined in the agreement, and follow our instructions.

Cookies After you have given us consent, we collect data from your personal electronic devices to register your online and mobile activities. We monitor data sessions to register your visits and use cookies to enable required functionality, increase the quality of our website or mobile services, optimise your personal experience and support promotional and direct marketing activities. You can read more about how we use cookies in the cookie statement included on our website and you have the option to disable cookies if required.