1. Important information and who we are
Privacy policy
This privacy policy gives you information about how THE LOAN CHECKER (TLC) LTD collects and uses your personal data through your use of this website, including any data you may provide when you engage with us, including when you contract to use our services.
TLC provides an independent audit service for commercial finance arrangements. Our role is limited to reviewing finance documentation to identify potential discrepancies or overcharges. TLC does not provide legal advice and does not manage legal claims. Where our audit identifies a potential issue, we may refer you to our vetted solicitor partners, who independently handle any legal recovery process. TLC has no direct communication with lenders regarding any issues identified through our audit process.
This website is not intended for children and we do not knowingly collect data relating to children.
Controller: THE LOAN CHECKER (TLC) LTD, a company incorporated in England and Wales under company number 15725484, is the controller and responsible for your personal data (collectively referred to as (“TLC”, “we”, “us” or “our” in this privacy policy).
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender. Special categories of data may also be processed where required to deliver services to you under a contract for our services.
- Contact Data includes any physical address, email address, social media and telephone numbers.
- Financial Data includes information relating to your commercial finance arrangements, such as loan agreements, facility letters, statements of account, interest and fee schedules, and associated correspondence. This data is collected solely for the purpose of conducting our audit service.
- Transaction Data includes details about payments to and from you and other details of services you purchase from us.
- Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website].
- Profile Data includes your username and password, purchases made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you interact with and use our website, and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We may also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you;
- apply for and/or purchase our services;
- create an account on our website;
- subscribe to our publications;
- request marketing material to be sent to you;
- give us feedback or otherwise 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 and other similar technologies. Please see our cookie policy [LINK] for further details[RP7] .
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data is collected from analytics providers, advertising networks, and search information providers.
- Identity and Contact Data is collected from publicly available sources, primarily the Companies House register. We access the Companies House public register (including the register of legal charges filed against companies) to identify businesses that may have commercial finance arrangements. This data is accessed via the Companies House API and is used under the Open Government Licence v3.0. We may also use other publicly available sources such as Land Registry records and business directories. Where we identify a company with registered charges that may indicate a commercial finance arrangement, we may use publicly available director and registered office information from Companies House to make initial contact. If you receive correspondence from us, this is the basis on which we obtained your details.
Legal basis
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
- Performance of a contract with you: Where we need to perform our contracted services with you.
- Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests. This includes contacting businesses that may benefit from our audit service, where we have identified from publicly available records that the business may have commercial finance arrangements. We consider and balance any potential impact on you and your rights before processing 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).
- Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
- Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter. Where we process any special categories of personal data, we will do so on the basis of your consent.
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 the various categories of 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.
The period for which we retain personal data is set out in paragraph 8 below.
Direct marketing
We may contact you by post where we have identified from publicly available records that your business may have commercial finance arrangements that could benefit from our independent audit service. We consider this to be a legitimate interest as set out above. Our initial marketing contact is by postal mail only. Any findings communicated in our marketing materials are indicative only and do not constitute a guarantee of recovery.
You may receive further marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving such marketing. You may opt out of receiving marketing communications at any time (see section 9 below).
Cookies
For more information about the cookies we use and how to change your cookie preferences: google.com/technologies/cookies.
We may share your personal data with the following categories of third party, where necessary for the delivery of our services:
Solicitor partners: Where our audit identifies potential discrepancies or overcharges, and you instruct us to do so, we will refer your case to our vetted solicitor partners. The solicitor partners independently handle all aspects of legal recovery, including any communication with lenders. TLC does not manage claims, provide legal advice, or communicate with lenders regarding audit findings. Your personal data will only be shared with solicitor partners with your explicit consent.
Third parties under Power of Attorney (POA): Where you engage our audit services, we may ask you to grant us a limited Power of Attorney. This POA authorises TLC to contact third parties who were involved in your finance arrangement on your behalf, solely for the purpose of gathering information needed to complete our audit. This may include your conveyancing solicitor, broker, or other intermediaries involved in the finance process. The POA does not authorise TLC to contact your lender. The POA is used only to collect information relevant to the audit and for no other purpose.
We may also share your personal data where necessary with law enforcement, banks, and credit reference agents as part of the services we provide.
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.
We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law. Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that appropriate contractual safeguards are in place. We may transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data. We may also use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement, or the International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers. To obtain a copy of these contractual safeguards, please contact us at the address below in paragraph 10.
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.
How long will you use my personal data for?
We will 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 will typically retain client data for six years from the end of our contract with you, in line with the typical UK limitation period. 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.
For individuals we contact through our marketing activities who do not engage with us or who do not become clients, we will retain personal data for no longer than 12 months from the date of our last communication, after which it will be securely deleted or anonymised. If you opt out of communications, your data will be added to our suppression list (to ensure we do not contact you again) and all other personal data will be deleted within 30 days of your opt-out request.
We maintain a data retention schedule which sets out the specific retention periods for each category of personal data we process. A copy is available on request.
In some circumstances you can ask us to delete your personal data – see section 9 below.
You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
- Request access to your personal data (commonly known as a “subject access request”).
- Request correction of the personal data that we hold about you.
- Request erasure of your personal data in certain circumstances.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that processing.
- Object to the processing of your personal data for direct marketing purposes. You can do this by contacting us or using a hyperlink contained in any electronic marketing communication we may send.
- Request the transfer of your personal data to you or to a third party.
- Withdraw consent at any time where we are relying on consent to process your personal data. Note that 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 services to you.
- Request restriction of processing of your personal data.
If you receive postal marketing from us and wish to opt out, you can do so at any time by:
- Writing to us at the address in section 10
- Calling us on 0800 772 0156
- Emailing us at [email protected]
We will action your opt-out request promptly and add your details to our suppression list to ensure you do not receive further marketing communications from us.
No fee usually required: You will not normally 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.
Time limit to respond: We try to respond to all legitimate requests within one month (30 days). 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. Contact details
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:
- Email address: [email protected]
- Postal address: 21 Marina Place, Hull, HU1 1TJ
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
12. Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review and will update its terms periodically.
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, for example a new address or email address.
13. Data source attribution
This privacy policy and TLC’s services make use of publicly available data from the Companies House register. Contains public sector information licensed under the Open Government Licence v3.0 (www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).