General

Cash Converters (UK) Limited (CCUK) and Cash Converters franchisees ("we", "us" or "our", "the group", "Cash Converters") collect personal information to provide you with the products and services you request as well as information on other products and services offered by or through us. We are committed to protecting the privacy of your personal information.

CCUK is a company registered in England and Wales with company number 03096334. Our registered office is Cash Converters (UK) Ltd, Artisan, Hillbottom Road, High Wycombe HP12 4HJ. CCUK is the franchisor to the franchisee owned store network in the UK. Each franchisee owned store is independently registered with the Information Commissioner's Office.

Please read this Privacy Policy carefully before submitting any information about yourself to us.

About this Policy

This Privacy Policy explains how and why we acquire and use your personal information in accordance with Regulation (EU) 2016/679 and the EU General Data Protection Regulation (GDPR) effective from 25th May 2018, when you visit our website (www.cashconverters.co.uk) or when you contact us or use our products and services. This includes any application, successful or otherwise, through the Cash Converters website or directly in a store.

By providing us with details, whether through the website or in person, you are accepting the information collection, use and other business practices disclosed in this Privacy Policy.

Who's the Data Controller?

For the purposes of data protection laws, Cash Converters (and any relevant Cash Converters Franchise store who you have provided information to) is the "data controller" of all personal information that is collected, used and/or otherwise processed under this Privacy Policy.

Why do we collect your information?

Any information you provide us, either using the internet or by any other means, is only collected for purposes which are reasonably necessary for, or directly related to, one or more of our business functions, products or activities. Products that require the collection of information include: Personal Loans, Cash Advance, Pawnbroking loans, Buyback, Buys and Laybys, and online purchases through the website. Please note that third party' brokers provide their own specific privacy notices.

These purposes include using and processing your information:

• to provide you with the products and services they request and to monitor, evaluate and improve products and services;
• to assist you with queries, resolve your complaints, or requests for access to information, or to manage any legal action involving us;
• to manage customer relationships or accounts and perform other administrative and operational tasks (including risk management, systems development and testing, credit scoring, identity verification, staff training, collecting debts and market or customer satisfaction research);
• to provide information on products and services offered by us, affiliated product and service providers, and external product and service providers for whom we act as agent (unless you have opted out);
• for debt collection and debt tracing;
• to comply with our legal obligations;
• to the extent otherwise permitted by law
• to identify you or to establish their tax status under any UK or foreign legislation, regulation or treaty or pursuant to an agreement with any tax authority;
• to gather and aggregate information for statistical, prudential, actuarial and research purposes;
• to develop and implement measures to detect or prevent unlawful activity, fraud, money laundering and credit loss; and
• any or all of these processes may be automated.

If we undergo re-organisation or are sold to a third party, you agree that any information we hold about you may be transferred to that re-organised entity or third party.

If you choose not to provide information which we require for the above purposes, we may be unable to provide you with the goods and services you request from us.

We will not otherwise transfer, disclose, sell, distribute or lease your personal information to third parties unless we have your permission to do so or are otherwise required or permitted to do so by law.

What information do we collect about you?

The personal information we collect from you is used to enable us to provide the specific service or product you have requested in store or is information required to assist you in using our website.

Personal information includes the following:

• user name and password for appropriate products applied for;
• your title, forename, and surname;
• your gender;
• your age and date of birth;
• residential status and address details for the past 3 years;
• country of residence and nationality;
• your personal email address;
• your personal contact details such as email addresses, your landline telephone and/or mobile telephone number(s), fax number and postal address;
• your employment status, current and past employer details, within the last 3-year period, and duration of time in post;
• work-related contact details such as email addresses, your landline telephone and/or mobile telephone number(s), fax numbers and postal address;
• financial information; bank details, including bank name and address, sort code, account number, account type and time at your bank;
• occupation, salary and regular outgoings;
• where you "like" us or make posts on our pages on social networking websites, such as Facebook, Twitter, YouTube and Instagram;
• where you review the products and services offered by Cash Converters on online review sites, such as Trust Pilot or Google Reviews;
• your unique agreement number to send you information, correspondence and statements regarding your account via email;
• photographic and/or video images/recordings; or
• information necessary for legal and regulatory compliance purposes.

In some instances, we may be provided with other types of information classified as Special Category Data. For example:

• information regarding health (physical or mental);
• religion; or
• trade union Information.

Data provided by you is done so voluntarily but we may also collect it where lawful to do so from (and combine it with information from) fraud prevention agencies, public sources, third party service providers (such as Experian Limited trading as HD Decisions who may conduct a soft credit search as part of our "identity confirmation service"), tax or law enforcement agencies and other third parties. We may also collect personal information about you from your use of our websites or services.

What website and internet usage information do we collect?

If you visit our website to read, browse or download information, our system may record the following information which is provided by your browser:

• the date and time of your visit;
• the type of browser and operating system you are using;
• standard internet and website log information to understand our website visitors use;
• your Internet Service Provider and top level domain name (for example - .com, .gov, .au, .uk etc);
• the address of any referring web site (for example - the previous web site you visited) and the website you visit after leaving our site; and
• your computer's IP (Internet Protocol) address (a number which is unique to the machine through which you are connected to the internet).

Website data is kept strictly confidential. It is used for internal research purposes and to provide goods and services that you request. It helps us monitor which sections of the site are most popular to give us a clear idea of what type of information and services to include on our site. It also informs us which members and subscribers are using the site so that we can customise the website information and presentation.

When you use one of our web sites, we may send you a "cookie" that gives you a unique identification number. A "cookie" is a packet of information that allows the server (the computer that houses the website) to identify and interact more effectively with your computer. A different identification number is sent each time you use one of our websites. These cookies may be Session cookies which only last until you close your browser, or they may be Persistent cookies which are stored longer term on your computer. Cookies do not identify individual users, although they may identify a user's browser type and your Internet Service Provider (ISP).

You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Please refer to your browser instructions or help screens to learn more about these functions. If you reject all cookies, you may not be able to use our websites or certain website functions may not work properly or at all.

Please see our separate Cookies Policy for more detailed information about how we use cookies on our website and how you may exercise your preferences around the use of cookies. Examples of our cookies include:

Collection via online forms

If you decide to complete an online application form, we will collect the information that you enter into the online form and the IP address of your computer. If you cancel your application prior to submission, any information entered on the current screen which has not yet been submitted, will be automatically deleted. Information you have already submitted to us prior to you cancelling your application may be used to contact you about your application, after which it will be automatically deleted. The deletion referred to above will happen within a reasonable period of time but in any event, no longer than 30 business days.

Collection of Telephone and CCTV recordings and images

We may also record telephone conversations and CCTV images to offer you additional security, resolve complaints, for staff training purposes, to improve our service standards and for fraud prevention measures.

Who do we disclose or share your information with?

We will not give your information to Government agencies, private sector organisations or anyone else unless one of the following applies:

• you have consented;
• you would reasonably expect, or have been told, that information of that kind is usually passed to those individuals, bodies or agencies;
• it is otherwise required or authorised by law;
• by your actions we consider you to have released us from our duty of confidentiality or to have consented to the disclosure of information about you without actually saying so (for example, if you discuss your financial position publicly with the media);
• it will prevent or lessen a serious and imminent threat to somebody's life or health; or
• it is reasonably necessary for the enforcement of the criminal law or of a law imposing a pecuniary penalty, or for the protection of public revenue.

Depending on the product or service Cash Converters has provided you with, we may disclose information to:

• affiliated product and service providers and external product and service providers for whom we act as agent (so that they may provide you with the product or service you seek or in which you have expressed an interest);
• auditors we appoint to ensure the integrity of our operations;
• any person acting on your behalf, including your financial adviser, solicitor, settlement agent, accountant, executor, administrator, trustee, guardian or attorney;
• your employer(s), referee(s), guarantor(s) or potential guarantor(s);
• if required or authorised to do so, regulatory bodies, government agencies or courts or anyone authorised by any one of them to receive such information;
• participants in the payments system (including payment organisations and merchants) and other financial institutions (such as banks);
• insurers;
• fraud prevention agencies, including overseas ones;
• any joint borrower(s) or account holder(s);
• credit reporting bodies or debt collection agencies;
• other financial institutions and organisations at their request if you seek credit from them (so that they may assess whether to offer you credit);
• other parties where you have consented to the disclosure;
• suppliers from whom we order goods or services on your behalf (so that the goods or services may be provided to you); or
• other organisations or individuals specified elsewhere in this Privacy Policy.

Keeping your Information

We will keep your information only for as long as it is reasonably needed by us for the purposes stated in this Privacy Policy and for a maximum of six years unless a longer period is required by any law or to the maximum time limit of any relevant statute of limitations in your area.

Direct Marketing and Your Preferences

We may wish to provide you with information about new products, promotions, special offers relating to Cash Converters, group companies and franchisees and other information which may be of interest to you and invite you to take part in market research. This communication may happen by post, telephone, email or SMS (unless you have asked us not to do so). We will obtain your consent where we are required to do so in accordance with the GDPR.

We will ensure that any direct marketing or market research that you receive or are contacted about by electronic means will provide a simple means for you to refuse further marketing. For example, in emails it may provide you with an ‘unsubscribe' link, or an email address to which you can send an opt-out request.

We will stop any marketing to which you object or withdraw your consent. You can change your mind at any time about marketing by informing us by emailing customerservices.uk@cashconverters.com

Your data may be used for other purposes for which you gave specific permission, when required by law or where permitted under the terms of the GDPR.

Online Advertising and Performance Tracking

We use several advertising companies to devise and deliver our online advertising. This often involves displaying banner advertisements on third party websites.

When you see one of our advertisements on a third party website, cookies and, in some cases, Spotlight tags are sometimes used to collect information such as:

• the server your computer is logged on to;
• your browser type;
• the date and time of your visit; and
• the performance of their marketing efforts.

When you visit our websites directly or after seeing one of our advertisements on a third-party website, anonymous information is collected on how you use our website. This might include which pages you view, and whether you start or complete an online application. The tracking companies aggregate all the captured information and use it to study internet user behaviour patterns.

They do not include personal information in their studies and use the data mainly to measure advertising effectiveness and relative consumer interest in the various areas of our websites. No personal information is collected during this process. If, however, any information is automatically collected, the tracking companies are required under their arrangements with us to maintain the privacy and confidentiality of that personal information.

We may disclose the information collected, in an aggregated form only, to third parties including advertisers or potential advertisers.

Links to other websites

Our websites may contain links to non-Cash Converters websites. While such links are provided for your convenience, you should be aware that the information handling practices of the linked websites might not be the same as ours and we encourage you to read and understand the privacy policies on these websites prior to providing any information to them.

Will my personal information be transferred abroad?

The personal information you provide to us is processed in the UK. It may be transferred to other group companies and to franchisees as described in previous paragraphs. Some of the companies to whom your personal information will be disclosed are located outside of the European Economic Area ("EEA"), in countries which do not provide the same level of protection to personal information (such as Australia and the United States). We will take steps to ensure that your personal information will be afforded the level of protection required of us under applicable data protection regulation and this notice.

Your rights in relation to information we hold about you

You may request details of personal information which we hold about you under the GDPR at any time (a Data Subject Access Request or DSAR). No fee will be required, although reasonable fees can be charged for manifestly unfounded or excessive requests. Your request will be responded to within one calendar month or any earlier time limit prescribed by law.

You have the following rights:

• to make changes or corrections to your information to make sure it is accurate and up to date;
• ask us to stop or limit our use or processing of your information or delete your information (we are not obliged to do this in relation to information we need as part of our contractual relationship or for compliance with other laws, such as taxation or accounting laws);
• receive a copy of the information we hold about you;
• withdraw consent you have previously provided;
• transfer your information to a third party; and
• the right to lodge a complaint about us to the UK Information Commissioner's Office (https://ico.org.uk/) or the relevant authority in your country of work or residence.

Please note that we reserve the right to retain certain information for our own record-keeping (for example, to ensure that you do not receive marketing communications that you have opted-out of receiving) and to defend ourselves against any claims. We may also need to send you service-related communications relating to the goods or services that we provide to you even when you have requested not to receive marketing communications.

You can exercise these rights by contacting us using the contact information at the end of this Privacy Policy. Please be aware that we may need you to provide additional information in order to process your request, such as to confirm your identity and/or to confirm what information you wish to access.

Acceptance and Changes to Privacy Policy

You acknowledge and accept that your use of Cash Converters website or of products which direct you to this Privacy Policy indicates your acceptance of our website terms of use and of the use and disclosure of information provided for under this Privacy Policy.

This is the current Privacy Policy. It replaces any other Privacy Policy for the Cash Converters website previously published on the Cash Converters website. Cash Converters may at any time vary the Privacy Policy by publishing the varied Privacy Policy on the Cash Converters website. When we make changes to this Privacy Policy, we will revise the "Last Updated" date on the final page of this Privacy Policy. You accept that by doing this, Cash Converters has provided you with sufficient notice of any variation.

If we make any changes that we think are material in the way we collect, use, and/or share your Personal Information, we will notify you by sending an email to the email address you most recently provided us in your account or registration (unless we do not have such an email address), and/or by prominently posting notice of the changes on our website. If we add new cookies to our website, change the data collected by current cookies, or what we use that data for, we will let you know the next time you visit our website and ask for your consent to their use.

We recommend that you check our website from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.

Contact Information

If you have a question, want to exercise your rights or make a complaint, please contact us using the details below and your question will be responded to as soon as possible and/or in accordance with our Complaint Policy.

If your question refers to a franchisee owned store we will forward the question within 24 hours between Monday and Friday.

You can contact us at:

Cash Converters (UK) Ltd, 5 Wellfield, Preston Brook, Runcorn, Cheshire, WA7 3AZ, email customerservices.uk@cashconverters.com.

If we cannot resolve your Pawnbroking complaint, you may contact the Financial Ombudsman Service at:

Financial Ombudsman Service
Exchange Tower
London
E14 9SR
Tel: 0800 234 567

You also have the right to complain about the use of your personal data to the Information Contact Centre, Commissioner's Office at:

Wycliffe House,
Water Lane,
Wilmslow,
Cheshire,
SK9 5AF

or www.ico.org.uk

This was updated on 13 April 2018