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Open Banking Privacy Policy

Effective from: 7 December 2023

 

ClearScore respects your privacy and protecting your information is paramount. ClearScore acts as  the data controller for the personal data that you provide us or that we collect in relation to the provision of our Open Banking Service to you (as defined in our Open Banking Terms and Conditions).

Please read this Privacy Policy carefully before using the Open Banking Service. This Privacy Policy (together with our Open Banking Terms and Conditions, the "Open Banking Terms") applies when you connect your bank account through us and use the Open Banking Services.

By using the Open Banking Services you are acknowledging you have read and understand the practices described in this Privacy Policy.

We are registered with the UK Information Commissioner’s Office (“ICO”) (ZA100119) and you can check our registration by visiting https://www.ico.org.uk/esdwebpages/search.

References in this Privacy Policy and on our website to "we", "our" or "us" are references to Clear Score Technology Limited. References to "you" and "your" means each natural or legal person who uses our website or the associated services. References to our website below include references to our apps as they relate to the Open Banking Services.

 

The information we collect

Information you give us. You may give us information about you when you use the Open Banking Services and when you communicate with us. This includes information you input during registration by answering specific questions on our website, providing us with feedback, participating in surveys, and when you can you report a problem.

The information you give us may include:

  • Your banking provider(s)
  • Monthly expenditure
  • Personal information or documents required to identify you
  • Financial goals and budgets
  • Lifestyle information

Information that we will receive from your bank or credit account provider (“Account Provider”).

Your Account Provider may share with us information about you contained in your account, which could include:

  • your bank account type and details
  • account number and sort code
  • account balance
  • bank account transactions (incoming and outgoing)
  • card balance
  • card transactions (incoming and outgoing)
  • account statements, including charges, rewards, statement period and account balance;
  • details of pricing, fees, interest rates, name and type of account, products or offers that may be available to you
  • any offer available to you on your account e.g. a balance transfer
  • other details from your account, such as standing orders or direct debits or scheduled payments, including dates, payees and amounts, reference

Special categories of data. The categorisation of some of your transactions may include special categories of data as it may be indicative of your political beliefs (for e.g., if you pay membership for a political party) or trade union membership.

Information we collect about you. We will collect information during your use of the Open Banking Services including (a) the details regarding the communications made between us; (b) technical information including the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; (c) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Information we receive from other sources. We may receive information about you from third parties if you use any part of the Open Banking Service. We work closely with third parties (including, for example, business partners, service providers, advertising networks, analytics providers, search information providers, social media) and may receive information from them

Information collected from cookies. We and our service providers collect information about your use of our website from cookies. For more on how we use cookies and how to decline them or turn them off please read our Cookies Policy.

How we use the information

We will use the information we hold about you to provide you with our Open Banking Service, as described in our Open Banking Terms and Conditions. That may include verifying your identity, combining or displaying Open Banking data alongside your credit report to provide you with information or insights, or obtaining quotes from credit providers. We also use your information to improve all of our services, administer your account and communicate with you.

We will also use the information:

  • on an anonymous or aggregated basis for research, profiling, analytical purposes;
  • to create anonymised research datasets and related market research services (in each case, from which all personal data is removed) and sell it to our clients, including clients of the ClearScore group, in return for revenue. We may also use such data to provide such clients with market research insights.

Information you give us or we collect from other third parties.

We will use this information to:

  • provide you with information, products and services;
  • analysing and reporting on your account and transaction data that we obtain from your bank;
  • contact you to ask you to refresh your consent for us to access your bank account;
  • contact you to inform you that your access to ClearScore Open Banking will be revoked due to your consent having lapsed;
  • pre-fill application forms of financial products you choose to apply for;
  • verify your identity as part of our identity authentication process;
  • where you have provided your consent for us to market to you, provide you with information about other products and services we feel may interest you or be best for you;
  • notify you about changes to our services;
  • ensure that content from our website is presented in the most effective manner for you and your device;
  • anonymise it and/or aggregate it with other data for data analytical and reporting purposes;
  • undertake analysis and profiling of your credit information in order to identify and inform you of credit products that we consider are likely to interest you or be suited to your credit circumstances or to enhance our services;
  • to ensure compliance with your requests for the exercise of your rights;
  • contact you via app ‘push’ notification with relevant information about ClearScore Open Banking, such as notifications about renewing your consent for us to access your bank account;
  • to manage our communications with you in relation to your queries or complaints.

Information we collect about you based on your use of our website.

We will use this information to:

  • to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve the service we offer you such as understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
  • as part of our efforts to keep our website safe and secure and to prevent fraud;
  • to make recommendations about products or services that may be of interest.

 

Data analytics.

We will use the information we hold about you to conduct analysis of it for the following purposes:

  • analysis of information about you on a personalised or aggregated basis to further tailor the experience to you and for marketing purposes;
  • verify the accuracy of data that we hold about you and create a better understanding of you as a ClearScore user;
  • use information about you, your spending and your use of the Open Banking Services with information in conjunction with other user’s information to identify patterns. When used in conjunction with other user’s data, it will be in an anonymised format;
  • to provide you with a better service by conducting statistical analysis and system testing to understand your needs;
  • network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;

Who we may share your data with

We may need to disclose your data to others to ensure the provision to you of the Open Banking Service and any information you request. We will share your data where we have your permission to do so in accordance with this Privacy Policy or where we believe it is necessary for a legitimate reason connected to our Open Banking Service.

Group company. We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

Our business partners. We may share your information with providers of products on our platform, such as our business partners who offer you credit cards, loans, car finance, mortgages, insurance, pensions, investments and other related products.

We may share this data with our partners to fulfil the following purposes:

  • to assess your probability of being accepted for a product;
  • to allow us or the partner to conduct analysis with the intent to better understand the market or to provide you with better products and services in the future, and/or for segmentation purposes;
  • pre-fill an application form with the product provider;
  • assess your affordability for a product;
  • to conduct income or identity verification
  • for fraud prevention purposes

Our partners will retain the information that was provided with your consent when you searched or applied for credit while you were using our Open Banking Service. The partners will process your data in accordance with their own policies, but there are strict rules around this processing.

Selected third parties. We may also share your information with selected third parties including:

  • third parties which enable us to provide you with the Open Banking Service such as cloud back-up and server hosting providers, IT software and third parties that provide communication services.
  • if we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets (or the buyer or seller’s advisers);
  • if we or part or all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Open Banking Terms and other agreements; or to protect the rights, property, or safety of Clear Score Technology Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
  • advertisers that require data, to perform services on our behalf, including selecting and serving relevant adverts;
  • market research organisations engaged by us to undertake customer satisfaction surveys and market research;

Fraud Prevention Agencies. We will share your personal information with fraud prevention agencies. If false or inaccurate information is provided and fraud is identified, details of this fraud will be passed to these agencies. Law enforcement agencies may access and use this information. We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.

What is the legal basis for us using this information?

Our lawful bases may include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (such as delivering the Open Banking Service to you) and our own legitimate interests.

You can find more information regarding the legal basis we rely on in your main Privacy and Cookie Policy

How long we keep your information for

How long we keep your information will depend on the purpose for which we use it, our obligations and your actions. We will only retain your information in an anonymised format for as long as is necessary for those purposes.

In regards to your bank account information, we will retain it in the following manner:

  • If you allow your consent to lapse without revoking or renewing it, we will retain your bank information for a period of 9 months after the date your consent lapsed. After this period, your bank information will be permanently erased or fully anonymised. You can always renew your consent before the end of the 9 month period;
  • If you actively opt to revoke your consent and unlink your bank account from the Open Banking Service, we will immediately erase all bank account information;
  • If you continue to renew your consent at the appropriate times, we will retain your bank information for no more than 7 years from the date of the original consent.

Your other personal information collected in accordance with this Open Banking Privacy Policy will be kept for a period of 7 years after it is no longer required to provide you with the Open Banking Service. We will, however, keep your information indefinitely in the event it is required by applicable law (even if you exercise your right to request the erasure of your data) or if it is permitted under applicable law to retain your information so long as the necessary protections are applied.

How we protect your information

We take the security of your data very seriously and use strict procedures to protect it. Whenever we transfer personal data outside of the UK/ European Economic Area, we ensure that appropriate safeguards are in place to protect the data.

All information you provide to us is stored on our secure servers.

We do our best to protect your personal data, but we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access, loss or damage.

Where possible, we try to only process your information within the UK and European Economic Area (EEA). If we or our service providers transfer personal data outside of the UK or EEA, we always require that at least one of the following safeguards are in place to protect the information when it is processed:

  • the destination country is deemed by the ICO or the European Commission to have an appropriate level of protection for personal data;
  • an International Data Transfer Agreement or Addendum as specified by the ICO, or the standard contractual clauses specified by the European Commission;
  • other valid transfer method in accordance with applicable laws.

 

Your rights

We will provide you with the necessary tools and contact details to be able to exercise your statutory rights regarding the information that we hold about you. You will be able to:

Correct your data. You will usually be able to amend any information that we hold about you that is inaccurate or incomplete through the settings in your account. Some information we receive about you from your bank can only be correct by your banking provider.

Request access to your data. You can ask for access to the personal data that we hold about you so that you can check that we are using your information in accordance with data protection law

Erase your data. You can ask us to fully or partially delete your information where there is no compelling reason for us to keep using it, although we will not be able to continue to provide the Open Banking Service. We reserve the right to keep your information if it is necessary for compliance with our legal obligations.

Download your data or send it to another controller. You can obtain a copy of the data you provided us in a machine-readable format. In addition, where certain conditions apply, you have the right to have such information transferred directly to a third party.

Object to the use of your data. You can ask that we no longer use your personal data where that use is based on a legitimate interest

Restrict the use of your data. You have the right to ‘block’ or suppress further use of your information in certain circumstances. When usage is restricted, we can still store your information, but may not use it further. We will not be able to continue to provide the Open Banking Service.

Right to withdraw consent. If you have given your consent for us to use your information, you have the right to withdraw your consent at any time. This can be done by contacting our Data Protection Officer.

For the exercise of any of your rights, you can also contact us at privacy@clearscore.com.

Changes we make to our privacy policy

Any changes we may make to our Open Banking Privacy Policy in the future will be posted on this page and, where we decide it is appropriate, notified to you by email. Please check back frequently to see any updates or changes.

Contact us

You can address any questions, comments, complaints or requests regarding this Open Banking Privacy Policy to the Data Protection Officer at privacy@clearscore.com.

Your right to lodge a complaint with the ICO

If you are not satisfied with our response to any complaints you raise with us or you believe our processing of your information does not comply with the data protection law, we suggest you contact our Data Protection Officer. However, you can make a complaint to the Information Commissioner’s Office (ICO) at any time.

Please see the ICO website for further information – https://ico.org.uk/make-a-complaint/.

 

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