Infact Consumer Support

Privacy Policy

Introduction

Welcome to Infact Systems Limited’s (‘Infact’) privacy policy. Infact 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. Please also use the Glossary to understand the meaning of some of the terms used in 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 Infact collects, processes and stores your personal data through your use of this website and its interaction with third parties. 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
Infact Systems Limited is the “controller” and responsible for your personal data (collectively referred to as "Infact", "we", "us" or "our" in this privacy policy). Infact’s core activity is to conduct business as a credit reference agency. We are in the process of becoming authorised and regulated by the Financial Conduct Authority (“FCA”). In relation to the use and distribution of your personal data, we comply with the Steering Committee on Reciprocity (SCOR) Principles of Reciprocity, a copy of which can be accessed here: https://www.scoronline.co.uk/principles/ . The other mainstream credit reference agencies (“CRA”s), including Equifax, TransUnion and Experian, are members of SCOR and have jointly drafted a separate document detailing how each commonly uses and shares personal data received about their customer’s and their customer’s businesses that is part of, derived from or used in credit referencing and fraud prevention activities. This document is called the ‘Credit Reference Agency Information Notice’ (CRAIN). Infact will abide by the principles laid out in CRAIN for the services that we provide but the mainstream CRAs provide a broader set of services to those that Infact sets out to provide to customers. Each CRA hosts their own copies of CRAIN at the following destinations:

  • Equifax: https://www.equifax.co.uk/crain
  • Experian: https://www.experian.co.uk/legal/crain/
  • TransUnion: https://www.transunion.co.uk/legal/consumer-centre#pc-credit-reference

DPO contact details
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy or our privacy practices, including any requests to exercise your legal rights, please contact the DPO using the details set out below. Full name of legal entity: Infact Systems Limited Full name of DPO: William Mason DPO email address: customer@infactsystems.com Postal address: Infact Systems Limited, 4.11 27-31 Clerkenwell Close, London, EC1R 0AT

Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on 15th March 2023. We may change this online privacy policy in future. If we make changes to this online privacy policy, we will post the revised privacy policy and its effective date on this website. 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.

Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. 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). Depending on your use of the website and any contact with us, 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, maiden name, middle name, last name, title, and date of birth.
  • Contact Data includes billing address, postal address, email address and telephone numbers.
  • Credit Data includes the name of the provider issuing credit, and information about the account such as open date, reference number, status, outstanding amount owed, the credit limit available and payment information relating to the account, including late payments and missed payments.
  • Financial Data includes bank account, payment card details and application salary data, income and expenditure information.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, device information, 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 purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Fraud Prevention Data includes information indicating an individual’s behaviour appears to be fraudulent, and where an individual may have been a fraud victim, or is vulnerable to a fraud breach.
  • 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 insights and analytics relating to ability-to-pay and propensity to repay such as disposable income, average balances and average number of open accounts 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. 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 may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.
We do not 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 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. If this is the case, we will notify you at the time.

3. How is your personal data collected?

To enable us to operate as a credit reference agency, it is necessary for us to collect and store numerous types of data about you. We typically do not have a direct relationship with you (except where you communicate with us directly), so we obtain this data from numerous sources, including directly from publicly available materials (for example, the electoral roll, the Office of National Statistics, government and published county court judgements) or from our clients (for example, where a lender provides information about you so that we can conduct a credit or affordability check). Infact typically acts as a controller in relation to all the data it receives from such clients, including where provision of this information is for us to locate a match to records we already hold in our database and which is then supplemented with additional information (for example, addresses linked to you, your relevant credit data or other attributes relevant to you) 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:
    • exercise your legal rights under this privacy policy
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • give us feedback or contact us.
  • 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 and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out in the GLOSSARY below:

4. How we use your personal data

We are required by data protection law to always have what is referred to as a “lawful basis” (i.e. a reason or justification) for processing your personal data. 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.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data. To help you understand how and why we use your data, we have summarised our primary uses of your personal data immediately below.

Summary of primary uses
a) Providing Credit References As a credit reference agency, we will receive personal data about you that is part of, derived from or used in credit related activity. The information we receive and process in relation to your credit activity, is used by Infact and our clients in ‘credit referencing activities’, which include:

  • Credit reporting and affordability checks (for example, information related to your financial standing guides lenders as to whether to accept your application for a loan or credit card).
  • Customer management for helping maintain information where you have a relationship with an organisation we work with.
  • Verifying data like your identity, your age, where you live, and preventing and detecting criminal activity, fraud and money laundering.
  • Tracing your whereabouts to assist in the return of money you are owed or to reclaim debt that you owe.
  • Statistical analysis including profiling of either you as an individual (for example, to generate a ‘credit score’) or a group of people (for example, the general financial standing of a region or city).
  • Data management to carry out certain processing activities to support Infact business operations.
  • Conducting checks and creating flags and triggers to prevent crime, fraud and money laundering by, for example;
    • checking details provided on applications for credit and credit related products and services
    • managing credit and credit related accounts or products or services
    • verifying details provided as part of insurance underwriting and the pricing of insurance policies and assessment of insurance risk including insurance claims
    • checking details on applications for jobs or as part of employment
  • Producing credit, risk, fraud, identity, affordability, screening, collection and insolvency scores and ratings.
  • Generating search footprints to keep a record of enquiries.

Please refer to the above-mentioned CRAIN for more details on these activities in relation to the Mainstream CRAs - each CRA hosts their own copies of CRAIN at the following destinations:

  • Equifax: https://www.equifax.co.uk/crain
  • Experian: https://www.experian.co.uk/legal/crain/
  • TransUnion: https://www.transunion.co.uk/legal/consumer-centre#pc-credit-reference

b) General Information Services Processing
In order to provide our services to clients and individuals, we need to undertake certain general background operational processing of your personal data, as follows:

  • Data loading – when data is shared with Infact by suppliers it is checked and validated for quality and age to ensure it is fit for purpose. This process is assessing for inconsistencies that will allow the Data matching process to perform effectively. We are looking for any potential problems with names, date of birth, addresses or other identifiers we use to match your data into the system accurately.
  • Data matching – when data is supplied to Infact we search the system using the information provided to see if we can find a pre-existing individual to match the new information to. We use as much information as we can to find the right individual in the system to keep their data up to date and accurate. Sometimes that process will match with limited information such as similar initials for two people living at the same address but we will use all information available to assign it to the correct individual and create a new one if we are not confident in matching to a pre-existing identity.
  • Data links – as Infact adds information into a database there are links created with other data that already exists in the system. This might be connections between information such as previous telephone numbers, email addresses, names and addresses.
  • Systems and product development/testing – data may be used to help support the development and testing of new products and technologies.
  • Legal compliance and general record keeping – we will process data where required by law (for example, in order to comply with our requirements as a FCA regulated business) and may retain data where necessary for record keeping, tax compliance and to defend against claims.

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.

Table showing the purpose, type of data, and lawful basis for processing
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To provide credit referencing, affordability, fraud and identity services to our clients
  1. Identity
  2. Contact
  3. Credit
  4. Financial
  5. Transaction
  6. Fraud Prevention
  1. Necessary for our legitimate interests (it is in our mutual interest to respond)
To respond to your enquiries and/or complaints, requests to exercise your legal rights
  1. Identity
  2. Contact
  1. Necessary for our legitimate interests (it is in our mutual interest to respond)
To create an account and to register you as a new customer
  1. Identity
  2. Contact
  1. Performance of a contract with you
  2. Necessary for our legitimate interests (it is in our mutual interest to provide you with a private log-in in order to access services)
To send you information relevant to any services you receive from us
  1. Identity
  2. Contact
  1. Performance of a contract with you
  2. Necessary for our legitimate interests (it is in our mutual interest that you be updated with pertinent information)
To manage our relationship with you which will include:
  1. Notifying you about changes to our terms or privacy policy
  2. Asking you to leave a review or take a survey
  1. Identity
  2. Contact
  3. Profile
  4. Marketing and Communications
  1. Performance of a contract with you
  2. Necessary to comply with a legal obligation
  3. 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)
  1. Identity
  2. Contact
  3. Technical
  1. 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)
  2. 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
  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communications
  6. 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
  1. Technical
  2. 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)
To establish and enforce our legal rights or to comply with a court order, law enforcement requirements or legal obligation, including but not limited to, identifying potential fraud Any relevant personal data Necessary to comply with a legal obligation
Using any relevant personal data in relation to the managing the proposed or actual sale, restructuring or merging or licensing of any or all part(s) of our business Any relevant personal data
  1. Necessary to comply with a legal obligation
  2. Necessary for our legitimate interests (in being able to sell or restructure our business and maintain continuity for us or a buyer)
To make suggestions and recommendations to you about services that may be of interest to you
  1. Identity
  2. Contact
  3. Technical
  4. Usage
  5. Profile
  6. Marketing and Communications
  1. Consent (where legally required)
  2. Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Where our processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. If you do decide to withdraw your consent, we will stop processing your personal data for that purpose unless there is another lawful basis that also applies and which we are relying on – in which case, we will let you know.

Promotional offers from us
We may use your Identity, Contact, Credit, 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 goods or services 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 using your personal data for the purpose of sending you marketing messages, including any profiling that is related to direct marketing, at any time by contacting us directly at customer@infactsystems.com. 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/service purchase, warranty registration, product/service experience or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
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 our DPO using the contact details above. 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.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • 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.
Where we do share your personal data, we operate comprehensive access control processes. For example, before we share data with any another organisation, we check that organisation’s identity, location and, where applicable, confirm any necessary legal registrations

6. International transfers

Infact is a UK based company and the majority of our processing of your personal data takes place within the UK. However, Infact may transfer your personal data outside of the UK and the European Economic Area (EEA). In addition, some of our service providers (please see above) may have processing operations in other jurisdictions. While countries in the EEA ensure a consistently high standard of data protection law other parts of the world do not offer the same level of legal protection relating to personal data. As a result, whenever we transfer your personal data out of the UK, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. Data security

Infact is based in the UK, and we keep our main databases here. All information and personal data held by Infact is stored either on encrypted services at a secure physical location (whether these be our own servers or those of cloud service providers that we use). Infact also has internal policies and controls in place to ensure that personal data is kept secure as well as to minimise the risk of any personal data being lost, misused, disclosed or accidently destroyed. 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.

8. 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. The mainstream CRAs may retain credit reference data for different periods of time. Information about the mainstream CRAs retention periods can be found at the following destinations:

  • Equifax: https://www.equifax.co.uk/crain
  • Experian: https://www.experian.co.uk/legal/crain/
  • TransUnion: https://www.transunion.co.uk/legal/consumer-centre#pc-credit-reference

The mainstream CRAs may review their data retention periods from time to time. 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.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact the DPO using the contact details provided above.

Right to complain
Infact works hard to give you the best possible service. We try to make it as easy as possible for you to share your concerns with us, and we want you to be happy with how we handle them If you have a complaint, please contact our DPO. If you’re unhappy with how Infact has investigated your complaint, you may have the right to refer it to the Financial Ombudsman Service (Ombudsman) for free. The Ombudsman is an independent public body that aims to resolve disputes between consumers and businesses like Infact. You can contact them by: Phone on 0300 123 9 123 (or from outside the UK on +44 20 7964 1000) or 0800 023 4567 Email at complaint.info@financial-ombudsman.org.uk Writing to Financial Ombudsman Service, Exchange Tower, Harbour Exchange, London E14 9SR Going to their website at www.financial-ombudsman.org.uk You can also refer your concerns to the Information Commissioner’s Office (or ICO), the body that regulates the handling of personal data in the UK.
You can contact them by:

  • Phone on 0303 123 1113
  • Email at casework@ico.org.uk (you need to add a subject line of 'Report a Concern')
  • Writing to them at First Contact Team, Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
  • Going to their website at www.ico.org.uk

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.

10. Glossary

Lawful basis
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Where Infact processes your personal data in our function as a Credit Reference Agency (as detailed above), we rely on our Legitimate Interests and those of our clients, which include:

  • Promoting responsible lending and helping to prevent over-indebtedness
  • Supporting customer management for the benefit of consumers and businesses
  • Helping prevent and detect crime and fraud, supporting anti-money laundering services and verifying identity
  • Supporting the development and testing of new products, services and technologies
  • Supporting data management activities as required by Infact
  • Supporting tracing and collections
  • Enabling employers to check the suitability of their current and prospective staff
  • Enabling insurers to calculate and price risk more accurately
  • Complying with and supporting compliance with legal and regulatory requirements
  • Commercial interests

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. We provide some of our services directly to individuals (for example, you may subscribe to receive a newsletter). Where we process your personal data to provide you with these services, our processing will be both because it is in our Legitimate Interests to provide these services to you and also on the basis that such processing is necessary to comply with our contractual obligations to you, as an Infact customer.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to. There are many situations where such legal obligations may arise from time to time but those most likely to impact our business (and result in the processing of your personal data) are as follows:

  • Where we are required to hold or share your personal data in compliance with FCA regulations and permissions;
  • Where a crime is suspected (including fraud or money laundering) and we are required to make appropriate notifications or assist with investigations.
  • Where we are required to comply with the instructions of a regulator, court or law enforcement agency.
  • To maintain records required by law or to evidence our compliance with laws.

Consent means processing your personal data on the basis that you are happy for us to collect your personal data, such as when you tick a box to confirm that you are happy to receive email newsletters from us, or ‘opt-in’ to a service. Except in relation to certain marketing activities, we typically do not rely on consent to lawfully process your personal data. Occasionally, there may be isolated processing activities which we undertake on the basis of your consent, which we will notify you of in the relevant consent form (or similar document).

Third Parties
We may receive personal data about you from various external third parties and public sources including but not limited to:

External Third Parties

  • Identity, Contact Data, Credit Information, Financial Data, Transaction Data, Profile Data from our clients including but not limited to; lenders, and banks, utility companies, mobile phone networks, retails and mail order companies and insurance companies
  • Identity and Contact Data from service providers such as local authorities and royal mail
  • Judgment Data from statutory public registers maintained by Registry Trust Limited
  • Insolvency Data from the Insolvency Service, the Accountant in Bankruptcy, The Stationary Office and Northern Ireland’s Department for the Economy – Insolvency Services, the London, Belfast and Edinburgh Gazettes and Registry Trust Limited
  • Fraud Prevention Data from Cifas or similar providers.
  • Technical Data and Usage Data from the following parties:
    • your personal device
    • analytics providers such as Google based outside the UK;
  • Contact, Financial and Transactional Data from our clients, providers of technical, payment and delivery services.
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK, CIFAS, HM Treasury

We may share your personal data with third parties including but not limited to:
External Third Parties

  • Members of the Infact credit data sharing arrangement (acting as controllers) - each organisation that shares personal data with Infact is also entitled to receive similar kinds of personal data contributed by other organisations. These organisations are typically banks, building societies, and other lenders, as well as other credit providers like utilities companies and mobile phone providers.
  • Other users of the Infact data who are not data contributors but contract with Infact for specific sets of information to support affordability, credit or other decisioning, analytics, customer management, tracing, collections and debt management services.
  • Resellers and distributors (acting as processors) – Infact uses other organisations to help provide its services to clients and may provide personal data to them in connection with that purpose.
  • Service providers acting as processors who provide IT and system administration services, call centre providers and security service providers.
  • Professional advisers acting as processors or joint controllers including compliance consultants, lawyers, bankers, accountants, auditors and insurers who provide compliance, consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators, the polices and other law enforcement authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Interested third parties in the event that Infact anticipates a change of control or the acquisition of all or part of our business or assets or with interested third parties in connection with the licensing of our technology.

Your Legal Rights
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. If the data turns out to be wrong, we will update our records accordingly. If we still believe that the data is correct after completing our checks, we will continue to hold and use it.

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, although you may contact us any time you may not have the right to be forgotten from our systems.

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 automated 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.