Last updated: March 2020
This privacy notice is to let you know how Fronted gathers and processes your personal information.
This notice provides you with information regarding your rights and obligations and explains how, why and when we collect and process your personal data.
We take personal data seriously. Anything containing personally identifiable information is kept safe and we have put in place appropriate technical and other security measures to protect it.
We are Fronted Holding Ltd and all subsidiaries. Our registered office is at Fronted, 81 Rivington Street, London, England, EC2A 3AY. We are registered in England and Wales under company number 12278750. We are registered on the Information Commissioner’s Office (ICO) Register under number: CSN0780570.
by post at Fronted, 81 Rivington Street, London, England, EC2A 3AY;
by email at [email protected]
Data collected about your use of our websites. Information about your device, network, and web activity.
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site.
We collect some of this information using the following technologies:
Data about you as a customer, prospect or subscriber. Terms are as per the below:
Data includes details such as your name, email address, address and product interests.
Deliver our products and services.
We use information to fulfil our contracts with you, and to deliver our products and services effectively. This allows us to:
Improve our products and services.
Market our products and services.
Prevent fraud and abuse.
Comply with local laws and regulations.
Sharing Your Personal Information
We share your Personal Information with third parties to help us use your Personal Information, as described above. Third parties assist us in our marketing efforts and to deliver our products to you and in the provision of our services.
We use Google Analytics and MixPanel to help us understand how our customers use the Site.
You can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
You can read more about how MixPanel uses your Personal Information here: https://mixpanel.com/legal/privacy-policy/. You can also opt-out of MixPanel here: https://help.mixpanel.com/hc/en-us/articles/360001113426-Opt-Out-of-Tracking
Though not currently trading, we will be working with a regulated AISP and Credit Reference Agency, Credit Kudos and other legitimate agencies. This policy will be updated to reflect how data will be used following our move to trade.
We may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful requests for information we receive, or to otherwise protect our rights.
Do Not Track
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
We are committed to ensuring that your information is secure. Appropriate security measures are in place to protect against loss, misuse or alteration of information collected from you, including measures to prevent, as far as possible, access to our databases by parties other than Fronted.
Retention of Data
We will retain your personal data for as long as we are required to under relevant legislation and regulation, and where no specific rules apply, for no longer than it is necessary for our lawful purposes. This will usually be no more than six years from the end of our relationship with you. The retention period of your personal data may need to be extended where we require this to bring or defend legal claims.
We may also retain data for longer periods for statistical purposes, and if so we will anonymise this.
Why do we collect and store data?
We will need to keep your personal information for as long as you are a customer.
After your relationship with Fronted ends, we may keep your data for up to 6 years for the following scenarios:
In some circumstances, we will keep your data for longer than 6 years if we cannot delete it for regulatory or legal reasons. If it is required to extend our retention period, we will continue to ensure that your privacy is protected and we will only use it for the specified reasons.
How can you amend your marketing preferences?
When we first collect your data, we will give you the opportunity to confirm your preferences. Any electronic marketing communications we send you will include clear instructions to follow should you wish to unsubscribe at any time.
You may also amend your contact preferences by emailing us at [email protected].
As a data subject, you have a number of rights:
Your data protection rights are subject to certain restrictions and conditions and financial organisations are required to retain a range of your information for legal and regulatory reasons including responsible lending and the prevention of financial crime.
Fronted is required to keep a record of the information reported to the Credit Reference Agencies about you and will therefore retain repayment information regarding your loan for six years from the date that the loan is settled/closed. If your account is recorded as defaulted, the data is kept for six years from the date of the default. This may be extended where we require this to bring or defend legal claims.
If you think that any of the personal data we hold about you is wrong or incomplete you have the right to challenge it.
We will not make a charge for handing your rights request, unless we consider it to be manifestly unfounded or excessive involving a disproportionate effort (particularly if this is repeated request). If you would like to exercise any of the rights outlined above, you can make it in writing by emailing [email protected].
We will assess your request and if we decide not to act upon it or place certain restrictions on it, we will inform you of our reasons for this.
You have the right to complain to us and to the data protection regulator, the Information Commissioner’s Office. Their address is: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. They can be contacted by phone on 0303 123 1113 (local rate) or 01625 545745 if you prefer to use a national rate number.
You can find details on how to report a concern at: https://ico.org.uk/make-a-complaint/
How do we link to other sites?
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at: [email protected].
v1.0 – Last Updated: March 2020