Koyoloans

Privacy Policy

Koyo respects your privacy

Koyo respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE DATA WE COLLECT ABOUT YOU
  3. WHY WE COLLECT DATA
  4. HOW IS YOUR PERSONAL DATA COLLECTED?
  5. HOW WE USE YOUR PERSONAL DATA
  6. DISCLOSURES OF YOUR PERSONAL DATA
  7. HOW DO CREDIT REFERENCE AND FRAUD PREVENTION AGENCIES USE YOUR DATA?
  8. HOW DO WE WORK WITH FRAUD PREVENTION AGENCIES?
  9. INTERNATIONAL TRANSFERS
  10. DATA SECURITY
  11. DATA RETENTION
  12. YOUR LEGAL RIGHTS
  13. COMPLAINTS
  14. CHANGES TO THIS PRIVACY POLICY

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy policy

This privacy policy aims to give you information on how Koyo collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to be a Borrower.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

BETR Technology LTD trading as Koyo is the controller and responsible for your personal data (referred to as "Koyo ", "we", "us" or "our" in this privacy policy). We are a company registered in England and Wales. Our company registration number is 11483187 and our registered office is at Huckletree Soho, Ingestre Court, Ingestre Place London, United Kingdom, W1F 0JL.

We are registered with the Information Commissioner’s Office under registration number ZA542101.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Email address: [email protected]

2. WHY WE COLLECT DATA

We need to collect certain types of information to allow us to make a decision on your request for financial products. We also need to comply with legal and regulatory requirements relating to anti-fraud, anti-money laundering, know your customer and responsible lending obligations.

We will only collect the information we need to be able to provide you with the service you have requested. You need to make sure that the information you provide is accurate, complete and not misleading. Your personal information may need to be disclosed when we are obliged to by law, for purposes of national security, taxation, defence of a legal claim or criminal investigations.

3. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • "Identity Data" includes first name, last name, date of birth, username or similar identifier, title, nationality, martial status, number of dependents, employment status and residential status.
  • "Contact Data" includes billing address, email address and telephone numbers.
  • "Financial Data" includes account number, sort code and bank name for direct debit purposes.
  • "Transaction Data" includes details about payments to and from you, other details of products and services you have purchased from us and day of month to take payments.
  • “Credit Risk Data” includes information about you that we receive from credit reference agencies and also information about your credit card, bank and savings statements, spending habits, regular payments, monthly earnings after tax, monthly rent or mortgage payments and other financial data that, with your permission, we receive from your credit card provider, bank or building society.
  • "Technical Data" includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • "Profile Data" includes your username and password, loans made to you, desired loan amount and duration, loan purpose, your interests, preferences, feedback and survey responses.
  • "Usage Data" includes information about how you use our website, products and services.
  • "Marketing and Communications Data" includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share "Aggregated Data" such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not generally collect any "Special Categories of Personal Data" about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. If we do collect sensitive personal information, we will ask for your explicit consent to our proposed use of that information at the time of collection.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Changes to your personal data

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

4. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • create an account on our website;
  • enquire about our products;
  • request marketing to be sent to you;
  • give us feedback or contact us.

We may also request a scan of an identity document if this is required for “know your customer” or anti-money laundering purposes.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, visit statistics such as Google Analytics and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details. We may also record within the browser information necessary for the functioning of the website, for example whether cookie consent has been agreed to or progress through online forms.

Third parties. We also collect personal information received from other sources such as data from credit reference agencies, open banking data (including name, address, bank account number, sort codes, balance, overdraft limit and statement information) and results of “politically exposed persons” or sanction checks.

5. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data if we have a legal basis for doing so. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you
To enable you to access and use our website and allow us to supply services to you

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to provide a service to you)

To provide you with information and materials that you request from us

(a) Identity

(b) Contact

Necessary for our legitimate interests (to respond to your queries and provide any information and materials requested, to generate and develop business)

To create and maintain a trusted and safe environment on the website and platform by:

(a) detecting and preventing fraud and other harmful activity

(b) conducting investigations and risk assessments

(c) verifying any identifications provided by you

(d) conducting checks against databases and information sources for fraud detection and prevention, risk assessment and harm prevention purposes

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

Necessary for our legitimate interests (to carry out checks to ensure prevention against fraud and other harmful activity and ensure the website and platform is safe and secure)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Use of cookies or similar tracking technologies for data analytics to improve our website and email marketing (to the extent this processes your personal data)

(a) Technical

(b) Usage

Your consent (For more information, please see our Cookie Policy

To make suggestions and recommendations to you about products or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)
Fraud prevention

As part of our financial services products we may use your information in order to be able to:

  • Search your record with credit reference and fraud prevention agencies to check and verify your identity (and the identity of any other individual named on your application) and collect your credit report (and that of any other individual named on your application). Credit reference agencies will keep a record of our enquiries, which may also be used by other organisations with access granted by the credit reference agencies. This may affect your ability to get credit. Please see sections 7 and 8 for further details about how your personal data may be used by credit reference and fraud prevention agencies.
  • Undertake appropriate checks to prevent or detect crime, money-laundering and or fraud.
Automated decision-making

When you apply for a loan or other credit facility, we have an automated decision-making process which will decide whether to:

  • accept your loan application or
  • decline your loan application or
  • refer your loan application for further checks and additional consideration by us.
How the automated processes make decisions

We will use automated processes to verify your identity and to carry out fraud, credit reference agency and affordability checks on you. These automated decisions are made in order to perform the contract between us, and also to comply with our legal and regulatory requirements.

Your name and address will be used to obtain information about you from, and carry out checks with, a credit reference agency. The credit reference agencies that we currently use for this purpose are Transunion and Equifax. Your number of dependants, employment status, monthly earnings, monthly housing expenses and loan purpose will be used to enhance our affordability assessment. We also use open banking data to perform affordability and anti-fraud assessments, collected and provided to us by TrueLayer and Salt Edge.

We may also collect and process additional proof of identity information, such as a scanned copy of your passport or other form of identification.

The creditworthiness and affordability checks use your personal information to evaluate the risk that you will not (or will not have sufficient income to) repay your loan. These automated processes enable a decision to be made as to whether it is appropriate for us to offer you the loan, in accordance with Koyo’s legal and regulatory obligations.

The fraud and identity checks are carried out so that we can comply with our regulatory obligations to detect and prevent fraud and other crime.

If you do not pass all of these checks then your loan application will either be refused or will be referred for further checks and additional consideration by us.

Your rights relating to automated decision-making

You have the right to request that we review or reconsider any decision that we make about your application which is based solely on automated processes. If you wish to exercise this right, please contact us as above.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased products from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, warranty registration, product/service experience or other transactions.

Cookies

For information about the cookies we use, please see our Cookie Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. DISCLOSURES OF YOUR PERSONAL DATA

WE WILL NOT SELL, RENT, LEASE OR OTHERWISE SHARE YOUR PERSONAL INFORMATION OTHER THAN AS OUTLINED IN THIS PRIVACY POLICY OR WITHOUT OBTAINING YOUR CONSENT BEFOREHAND.

We may share your personal data with the parties set out below for the purposes set out in the table above.

  • Credit Reference Agencies (“CRAs”) and Fraud Prevention Agencies (“FPAs”).
  • Firms and businesses that help us provide you with the right product and services.
  • Service providers and business partners who assist with the running of the website and the operation of our business including hosting providers and payment processors. For example, personal data is shared with (amongst others):
    • Welcom Digital, who provide software as a service for back office management of loans;
    • Bottomline, for direct debit payment collection;
    • TransUnion, who perform politically exposed person and sanction checks;
    • TransUnion, who perform identity and veracity checks;
    • TransUnion, who provides consumer credit reports;
    • Equifax, who provides consumer credit reports; and
    • Other third parties used for the sending of emails and SMS messages.
  • Professional advisers acting as processors or controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or controllers who require reporting of processing activities in certain circumstances.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. HOW DO CREDIT REFERENCE AND FRAUD PREVENTION AGENCIES USE YOUR DATA?

When you apply to us for a loan, we will check the following records about you (and others where applicable):

  • Any records we may already have about you;
  • those held by CRAs; and
  • those held by FPAs.

CRAs supply us with public information (including from the electoral register, county court judgments and bankruptcies registers) and shared credit and fraud prevention information, including information about previous applications and the conduct of accounts in your and your financial associate(s)' name(s).

You should be aware that whether or not your loan or savings application is successful, when CRAs receive a search from us they will place a soft search footprint on your credit file that may be seen by other lenders. Large numbers of applications within a short time period may affect your ability to obtain credit. This is applicable whether your application is accepted or declined.

We will send the information that you submit through our website to CRAs. This information will be recorded by them. We and other organisations may access and use this information to prevent fraud and money laundering and CRAs and FPAs may use your information for statistical analysis. Information held by CRAs and FPAs will be disclosed to us and to other organisations in order to (for example):

  • prevent fraud and money laundering and to check and assess applications for credit, credit related facilities or other facilities;
  • recover debts that you owe and trace your whereabouts;
  • manage credit accounts and other facilities and decide appropriate credit limits;
  • verify your identity;
  • make decisions on credit and other facilities for you or your business;
  • check details on proposals and claims for all types of insurance; and
  • check details of job applicants and employees.

When you borrow from us, we will give details of your loan and how you manage it to the CRAs. If you borrow and do not repay in full and on time, the CRAs will record the outstanding debt and, in some cases, the length of time that the debt remains outstanding. Other organisations may see these updates and this may affect your ability to obtain credit in the future.

If you fall behind with your payments and a full payment or satisfactory proposal is not received within 14 Days of a “Notice of Default” being issued then a “Formal Demand” will be issued and a default registered on your Credit File with CRA’s.

This information may be supplied to other organisations by CRAs and FPAs to perform similar checks and to trace your whereabouts and recover debts that you owe.

If you give us false or inaccurate information and we have reasonable grounds to suspect fraud or we identify fraud we may record this and may also pass this information to FPAs and other organisations involved in crime and fraud prevention including law enforcement agencies who may then access this information.

The Credit Reference Agencies that we use are Transunion and Equifax.

If you have any further questions about our use of Credit Reference Agencies (or would like to receive details of these agencies) please email us using the contact details provided above in this Privacy Policy.

Equifax, Experian and TransUnion, the ICO and the major financial services trade associations have developed a common statement, Credit Reference Agency Information Notice (CRAIN). This defines the standards that all three Credit Reference Agencies will apply across all products and services in relation to processing consumer data. This can be found here.

8. HOW DO WE WORK WITH FRAUD PREVENTION AGENCIES?

We undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity before we make a decision about your application. These checks require us to process personal information about you.

We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

We process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested.

Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services or financing you have requested, or to employ you, or we may stop providing existing services to you.

A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you.

9. INTERNATIONAL TRANSFERS

Personal data is stored on secure servers hosted in the UK. We do not transfer your personal data outside the UK or the European Economic Area.

10. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11. DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

12. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

"Request access" to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

"Request correction" of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

"Request erasure" of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

"Object to processing" of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

"Request restriction of processing" of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

"Request the transfer" of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to information which you initially provided consent for us to use or where we used the information to perform a contract with you.

"Withdraw consent at any time" where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us as above.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

13. COMPLAINTS

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

14. CHANGES TO THIS PRIVACY POLICY

We keep our privacy policy under regular review. This version was last updated on October 21st 2019.

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