Privacy Policy

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Who are we?
Why do we have this privacy policy?
Our Service
How do we collect your personal information?
What personal information do we collect about you?
How do we use your personal information?
Purposes for which we use your personal information
How long do we keep your personal information for?
Who do we share your personal information with?
Automated Decision Making
What are your legal rights?
Is your personal information transferred outside the EEA and/or the UK?
Data Security
Complaints and contact details of our data protection officer
How we use cookies
Changes to this privacy policy

1. Who we are?

We (Digitonomy Limited) are a credit broker, authorised and regulated by the Financial Conduct Authority (FRN 690249). Growing Power is one of our trading styles, and we host this website. We are based in Chester, and our registered office is at the Steam Mill Business Centre, Steam Mill Street, Chester, Cheshire, CH3 5AN. Our registered company number is 08385135. We are registered with the Information Commissioner's Office with registration number ZA007309.

2. Why do we have this privacy policy?

The purpose of this privacy policy is to give you a clear explanation about how we use the personal information we collect from you when you use one of our websites to find a financial product or service. It is important that you read it in full to understand the information we need to collect from you, how we will use it and how you can access, update and delete your personal information. It should be read together with our Terms and Conditions

If you are re-directed to, or click on a link that takes you to a third-party website that is not ours, we will not be responsible for how they use your personal information. You should read their privacy policy to understand how they may use your personal information. Other than the information in section 9 (“Who do we share your personal information with?”), this privacy policy only explains how we will process your personal information.

“Personal information” in this policy means any information that we collect that could identify you such as for e.g. your name, address and online identifiers like your IP address.

3. Our Service

When you ask us to search for a financial service or product, we will use the personal information you provide to us in the different ways described below to deliver “Our Service”.

We are a data controller in relation to the personal information you have given to us, and we store this in a UK data centre.

We share the personal information you have given to us on your application form with Equifax Limited who are a credit reference agency (“CRA”) to carry out a soft search on you. This enables us to check your identity and creditworthiness (ie how likely it is that you will be able to repay the credit) so that we can assess which lender(s) may be more suitable for your financial circumstances.

We then share your personal information with our panel of financial services firms who are authorised to provide the product or service you are looking for, (“Our Partners”). If we cannot find the product or service you are specifically looking for, we may transfer you directly to alternative firms who provide other types of products and services such as credit builder tools, (these could incur a monthly fee if you choose to use them) debt advice or buy now pay later options.

Our Partners are separate data controllers when they receive this information, and they may process it for their legitimate interests to see whether they can provide you with the financial service or product you are looking for. For example, if you are enquiring about:

A loan:

Our Partners include our panel of lenders, together with other credit brokers who operate their own panel of lenders and brokers. They will carry out a loan eligibility assessment and make an automated decision about you such as a soft search. (Please see point 10 below for more information about this and what rights you may have as a result).

Where you have been successful with your search for a loan, you will either be re-directed immediately to Our Partner’s website to complete your application, or we may present you with offers for products and services that you could be eligible for. If you decide to proceed with any of these offers, you will then be re-directed to Our Partner’s website to complete your application.

Our Partner will provide you with the terms and conditions for that loan product. If you decide to complete your application, they will also carry out their own identification and validation checks (including fraud prevention procedures, affordability and credit application checks), in accordance with their own criteria. Any full credit check, (also known as a "hard" search) carried out by any of Our Partners will be visible on your credit file to any other lender in the future.

Where you have been unsuccessful with your initial search for a loan and we have been unable to identify a suitable alternative product or service to automatically connect you with, we will present you with other options from Our Partners who provide different financial products or services that we think may be of interest to you, for example a guarantor loan, debt solution or banking product. If you choose to proceed, we will share your personal information with Our Partner so that they can assess whether or not they can help you.

A credit card:

We will check your eligibility by sharing the information you have given to us with our providers of pre-screening and eligibility checking services (HD Decisions - an Experian business, Madison CF UK Limited, trading as 118 118 Money and Capital One (Europe) plc) and certain members of our panel of credit card issuers, (who may then also contact credit reference agencies "CRAs"). We refer to these firms as "Our Providers."

Pre-screening means Our Providers use your information to carry out a soft search on you. This is a pre-application check of your credit record and will not have any impact on your credit rating. (Please see point 10 below for more information about this and what rights you may have as a result).

Our Providers will also use their internal databases, scoring methods and knowledge of acceptance criteria to determine your likelihood of being accepted, ("Eligibility Checks").

You will then be presented with those credit cards that you may be eligible for and will have the opportunity to apply directly with one of Our Partners. If you do this, we will share your information with Our Partner, and you will be re-directed to their website to complete your application.

Our Partner will provide you with terms and conditions for the credit card you are applying for, and if you decide to complete your application, they will also carry out their own identification and validation checks (including fraud prevention procedures, affordability and credit application checks), in accordance with their own criteria. Any full credit check, (also known as a "hard" search) carried out by any of Our Partners will be visible on your credit file to any other lender in the future.

Before completing and submitting any application on one of Our Partner’s sites, you should read their privacy policy to satisfy yourself how they will process your personal information. We are not responsible for the way in which any of Our Partners may do this.

4. How do we collect your personal information?

We collect personal information from you in the following ways:

4.1 Information you give us.

Information you give us when you complete any online forms on our website to use Our Service.
Information you provide when corresponding with us by phone, email, WhatsApp and text message, or when you interact with us using social media such as Twitter, Facebook or Messenger etc. This includes information you might give us when using Our Service, leaving a review, or if you need to ask us a question, report a problem with our site or if you otherwise contact us.

4.2 Information we collect from you.

Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal information by using cookies and other similar technologies. Please see our cookie policy for further details.

4.3 Information we receive from third parties.

Pre-Screening and Eligibility Check data we receive from Our Providers.
Information about your credit and financial situation from CRAs when we carry out a soft search upon you ("CRA Information").
The outcome of any full applications that are made for a financial service or product you make as a result of using Our Service from Our Partners and from any third-party service providers we work with.

5. What Personal information do we collect about you?

In order to provide Our Service, we need to collect the following personal information about you:

Identity information: this includes your first and last name, and your date of birth.

Contact information: this includes your address; telephone number(s), and your email address.

CRA Information: this includes information about your financial status and eligibility for the products and services we offer.

Financial information: depending upon the financial product or service you are seeking, this could include details of your bank account; a breakdown of your income and expenditure (including information about your debts); rent/mortgage repayments; child care costs (if relevant); the amount of money you are looking to borrow; the length and purpose of any loan; other loans that you may have recently taken out; the date you are paid each month, and whether you have a debit card.

Employment information: this includes your employment status; the name of your employer; your job title, and the time you have been in your current job.

General information: this includes your homeowner status, your relationship status and the number of any dependents you may have.

Marketing and communications information: this includes your preferences in receiving marketing information about our similar products and services.

Technical information: this includes your internet protocol (IP) address used to connect your computer to the internet; your browser; time zone setting; your operating system and platform; the source of your enquiry (for example Google, Facebook, Bing etc) and the device that you are using. We also collect information about your visit to our site including the full Uniform Resource Locators (URL) to, through and from our site (including the date and time); page response times; download errors; lengths of visits to certain pages; page interaction information (such as scrolling; clicks and mouse-overs); methods used to browse away from the page, and, if you visited our site from a search engine, the address of that search engine and the search term you used.

Please note: it is your responsibility to check and ensure that any information you provide is correct, complete and accurate. If you fail to provide your personal information where requested, we will not be able to provide you with Our Service.

6. How do we use your personal information?

We can only use your personal information where it falls into one or more of the following categories:

It is necessary to fulfil a contract we have with you;
You have provided your consent;
We have a legal or regulatory obligation to do so;
It is necessary to carry out a task which is in the public interest;
It is necessary to protect your vital interests, or
It is in our legitimate interest to do so and it is not against your rights.

Soft opt-in is an exception to the general requirement to obtain consent before sending direct marketing to you by electronic means (such as email or text message or WhatsApp for example) and applies where you have previously engaged with us (for example by submitting your contact details on our website to make an enquiry about Our Service), and we are marketing our similar products and services. Under the ‘soft opt-in’, we will assume you still want to hear about our other related products and services until you opt out or unsubscribe. For most customers, this is beneficial as it allows us to tell you about our other similar products services that we think would be useful to you alongside the specific one you originally expressed an interest in.

Marketing: we will only contact you in response to a request or communication from you, where we have your consent or under the soft opt-in. Any such contact may be by email, text message, WhatsApp, push notifications, social media or other electronic means. We will not send unsolicited marketing communications to you about any other types of products or services.

Third-party marketing: we will not share your personal information with any company outside our company for their marketing purposes.

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. For more information about the cookies we use, please see our cookie policy.

Change of purpose: we will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Where we need to comply with a legal or regulatory obligation: we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

7. Purposes for which we use your personal information

We have set out below, in a table format, a description of the ways your personal information could be used by us, and which of the legal bases we rely on to do so. Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To enable you to:

Use Our Service, and
Be matched with the most appropriate Partner(s) on our panel, we will carry out a soft search of your credit file before sharing your personal information with our Partner(s).

(a) Identity information

(b) Contact information

(d) Employment information

(e) CRA information

(f) General information

Necessary for our legitimate interests (to operate and improve our business) by helping you to find the product or service you are using Our Service to find.

Necessary for our legitimate interests (to operate and improve our business) by transferring you directly to alternative firms who provide services such as debt advice, buy now pay later or credit builder tools where we are unable to find the product or service you were originally using our website to find.

To enable us to contact you by email and re-direct you to one of our websites where you have expressed an interest in using Our Service by submitting a form on a social media platform,such as Facebook for example.

(a) Identity information

(b) Contact information

Necessary for our legitimate interests (to operate and improve our business) by helping you to find the product or service you are using Our Service to find.

To assess your eligibility for a product or service. For example, if you are enquiring about a loan, you will be able to use our Eligibility Checker tool to assess your chance of being accepted.

If you are enquiring about credit cards, you will be able to check your eligibility by sharing your information with Our Providers of Pre-screening and Eligibility Checking services (HD Decisions - an Experian business, Madison CF UK Limited trading as 118 118 Money and Capital One (Europe) plc) and certain of our panel of financial services firms.

(a) Identity information

(b) Contact information

(d) Employment information

(e) CRA information

(f) General information

Necessary for our legitimate interests (to operate our business in providing and improving Our Service.)

To enable us to communicate with you:

(a) About your enquiry and any of our similar products and services (unless you have asked us not to) using the contact details you have given to us.

(b) About other products and services that we think you might be interested in where you have given us your consent to do so.

(d) To ask you to complete a survey, take part in a prize draw competition or provide us with feedback, testimonials or reviews

(a) Identity information

(b) Contact information

(a) Necessary for our legitimate interests (to operate our business in providing and improving Our Service, by remaining in contact with you about your enquiry and our similar products and services.)

(b) Necessary to comply with a legal obligation

To enable us to determine your eligibility for different products and services and either present you with (or exclude you from receiving) certain advertisements about those products and services that we believe will be relevant to you and that you will be interested in, we may use your personal information to create a profile of you and your circumstances. These advertisements may be sent directly from us (unless you have asked us not to), or be presented to you via TV, radio, out-of-home advertising, digital advertising networks and social media companies such as Facebook, Google and Snapchat for e.g.

Where we identify that it may be unsuitable for you to receive certain credit related marketing material, we may share a limited amount of your personal information with other members of our group and our third-party partners so that you do not receive it.

We believe we have a legitimate interest to profile your personal information in this way in order to comply with FCA regulation as a responsible credit broker by not inviting you to apply for credit which may be inappropriate for you. However, you have the right to object if you do not want us to do this. In this case, please see section 11 for details regarding your right to object to your personal information being used in this way.

(a) Identity information

(b) Contact information

(d) Marketing and communications information

(e) Technical information

(f) CRA information

(a) Necessary for our legitimate interests (of improving and developing our business and the products and services we are able to identify that could be relevant to you and the way that we are able to communicate this to you).

(b) Necessary to comply with a legal obligation

To enable us to improve Our Service and share information with CRAs so that we can analyse patterns and trends that will help us to identify the most relevant product or service for you, and improve our ability to show you relevant adverts at the right time.

(a) Identity information

(b) Contact information

(d) Employment information

(e) General information

(f) Marketing and Communications

Necessary for our legitimate interests (to provide you with the most appropriate product or service for your needs and to provide you with relevant adverts).

To manage our relationship with you which will include:

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

(b) Sharing your email address with a third party so that they or we can ask you to leave a review or take a survey

(a) Identity information

(b) Contact information

(a) Necessary to comply with a legal obligation

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

To administer, improve and protect our business and this website (including pre-populating a form with your personal information, training, troubleshooting, data analysis, testing, system maintenance, research, support, reporting and hosting of data)

(a) Identity information

(b) Contact information

(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 use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Identity information

(b) Contact information

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 improve our marketing strategy)

8. How long do we keep your personal information for?

Unless required by law to keep your personal information for a different period of time, we will keep it for no longer than 12 months from the date you last used Our Service or until you ask us to delete it.

9. Who do we share your personal information with?

When you use Our Service, your information will be shared with the following third parties or categories of third party:

Our Providers: when you check your eligibility for a credit card through our site, we will share the information you provide to us with Our Providers of Pre-screening and Eligibility Checking services. Please note that the following privacy notices will apply to the relevant third party's handling of your data, alternatively details can be found on their individual websites:

HD Decisions Limited (an Experian business) Privacy Notice (provider of eligibility scoring across a range of Our Partners and their products)
Capital One (Europe) plc Privacy Notice (provider of eligibility scoring for Capital One products)
Madison CF UK Limited trading as 118 118 Money Privacy Notice (provider of eligibility scoring for 118 products)

Our Partners: to help you find the financial product or service you are using our website to find, and to send you marketing communications if you gave them your consent to this. If you are searching for a loan or credit card product, Our Partners comprise a panel of consumer credit lenders, brokers and credit card issuers.

If you have been unsuccessful with your search for a loan or credit card, Our Partners comprise financial services firms who (where required), are authorised and regulated by the Financial Conduct Authority to provide debt counselling services, debt solution products, credit broking, credit information services, buy-now-pay-later products, e-money issuance and payment services and can offer a range of alternative financial products and services including, for example, a range of credit reporting tools and debt advice.
Broadcasting networks (such as TV and radio stations), media buying and advertising networks, and social media companies (such as Facebook, Google and SnapChat) so that we can present relevant advertisements to you.
CRAs : to help us to improve Our Service, we occasionally share customer personal information with CRAs. They aggregate this information so that no one can be identified. We can then analyse patterns and trends that help us to identify the most appropriate product or service for you and improve our ability to show you relevant adverts at the right time that may be of interest to you.
We also share your information with CRAs to process your application, check your identity and creditworthiness so that we can assess which of Our Partners may be more suitable for your financial circumstances.
For example, we share your personal information with Equifax Limited who are a CRA. As a result, they give us information about you, and anyone you may have a financial association with (e.g. a joint mortgage or joint bank account). Equifax will record a footprint on your credit file that we have requested. This search footprint will be visible only to you and will not affect your credit score.
For more information about how Equifax may use your personal information, you can read the Credit Reference Agency Information Notice here, or you can ask Equifax for a copy. You can also read Equifax’s privacy policy here: https://www.equifax.co.uk/ein.html.
Other companies who enable us to provide Our Service or who provide services to us, for example IT Service Providers (who provide for e.g. technology platforms or other IT services including data storage), communication providers (who provide for e.g. WhatsApp, email, and text services for customer contact and marketing purposes); marketing data analysis providers (who provide for e.g. audience insights and analysis), and customer review and rating platforms (who collect, manage, and display feedback from customers to enable us to to build trust and gather insights from customer experiences)

These third parties help us to provide Our Service. In order that they can do this, we may need to let them process your personal information. We will make sure that they keep the information secure and in accordance with our instructions, the UK General Data Protection Regulation 2016 (“UK GDPR”) and other UK privacy legislation.

We will also share your personal information when we have your consent, or where we are obliged to do so for a legal or regulatory reason, for e.g. to prevent or detect crime, for compliance monitoring or to enforce or apply our Terms & Conditions and other agreements.

Finally, we may also share your personal information with any 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 information in the same way as set out in this privacy policy.

10. Automated Decision Making

An automated decision is one where a computer or system is used to assess the information you provide to make a decision about you. We do not make automated decisions about you however, Our Partners may do this when we share your personal information with them so that they can make an assessment of your eligibility for Our Service. An example of this is the soft search that Our Partners will carry out upon you if you make an application for a loan or credit card with them.

(Note: a “soft” credit search helps Our Partner to decide whether or not they may be able to lend money to you. Unlike a “hard” credit search, a soft search is recorded on your credit file, but only you rather than any other lender will be able to see it. A soft search does not therefore affect your credit rating.)

As a result, you have the right to ask Our Partners that they do not make a final decision based solely on automated means. You can also object to the automated decision and ask that a person reviews it. If you ask us, we can tell you which of Our Partners has made an automated decision about you. To exercise this right, you will then need to contact Our Partners directly.

11. What are your legal rights?

Right to Object - because you have asked us to help you find a financial product or service, we need to process the personal information you give us to enable us to find the best product or service available amongst Our Partners. You can object to this processing (including any profiling and/or direct marketing that we carry out) at any time by sending us a message via growingpower.co.uk/contact, or by writing to the Customer Support Manager at Digitonomy Limited, Steam Mill Business Centre, Steam Mill Street, Chester, Cheshire, CH3 5AN. We will action any request you make promptly, although this will mean that we will not be able to help you find the financial product or service that you asked us to search for.
Right of Access - you can ask us at any time to confirm whether we hold your personal information, and if so you can access it by writing to us at: Data Subject Access Request Department, Digitonomy Limited, Steam Mill Business Centre, Steam Mill Street, Chester, Cheshire, CH3 5AN or by sending us an email.
Right to rectification - if we hold personal information about you that is inaccurate, you can ask us to correct it, and we will do this as quickly as possible.
Right to erasure - if it is no longer necessary for us to hold your personal information bearing in mind the reason why you provided it to us, you can ask us to delete it. If you ask us to do this, we will delete your personal information as soon as possible although this will mean that we may not be able to help you find the financial product or service that you asked us to search for.
Right to restrict our use of your information - you can ask us to restrict our processing of your personal information if you think for example that the personal information you gave us is inaccurate. This may mean that we may not be able to help you find the financial product or service that you asked us to search for.
Right to complain to the Information Commissioner’s Office (ICO) - we will try to resolve any complaint that you may have in relation to data protection issues. If you are not happy with our final response you have the right to have your complaint dealt with by the ICO. See section 14 - “Complaints and contact details of our data protection officer.”

12. Is your personal information transferred outside the European Economic Area (“EEA”) and/or the UK?

Although we do not routinely transfer personal information outside the UK, we may sometimes need to do this where any of our Partners or third-party suppliers are either based outside the EEA and/or the UK, or where they use data processors based outside the EEA and/or the UK. Where this is the case, we will make sure that they agree to: keep your personal information secure; apply the same levels of protection as we are required to apply to information held in the UK, and to use it only for the purpose of providing Our Service. We will do this by putting in place appropriate safeguards and protections as stated under UK law, for example using a data-transfer agreement incorporating certain standard model protection clauses.

13. Data security

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

14. Complaints and contact details for our data protection officer

We want you to be confident that we are handling your personal information responsibly and in line with good practice. If you are concerned that we are not doing this, you should contact us immediately. We will treat your concern seriously and work with you to try and resolve it.

Please address your correspondence to:

The Data Protection Officer

Digitonomy Limited

The Steam Mill Business Centre

Steam Mill Street

Chester

CH3 5AN.

15. How we use cookies

When using this website, some information may be collected automatically using cookies or other similar technologies. The information that may be collected includes your IP address, operating system and browser type, in order for us to learn aggregate information. This is never used to identify any individual, but does allow us to present you with a consistent experience when using our website. With your consent, we may also use cookies for advertising and marketing purposes.

Whilst we cannot control adverts you may see on other websites and in your social media feeds, you are free to opt-out of or change your settings regarding ad personalisation at any time, by going to your Google Ads Preferences Manager or Facebook Ad Preferences

You can disable delete or block cookies at any time on your device. If you wish to do this, you will need to use your internet browser settings as they each have their own way of allowing you to access and control these settings.

For more information about our use of cookies and how to disable them in your internet browser you can read our Cookie Policy here

16. Changes to this Privacy Policy

Any changes we may make to our privacy policy in the future will be posted on this page.

Please check back frequently to see any updates or changes to our privacy policy. However, if any significant change that we make affects the way that we are able to use your personal information (meaning that it would be unlawful for us to continue to use it), then we will do our best to communicate this to you.

Version 2.18

Last updated 30/10/2024