Privacy policy

Introduction

Level are committed to protecting and respecting your privacy.  Level is the trading name of Integro Funding Limited, which is a limited company registered at 20-22 Wenlock Road, London, N1 7GU, company number 10467450.

“We”, “our” or “us” means “Level” the trading name of Integro Funding Limited. For the purposes of data protection law, we are a data controller in respect of your personal data.  We collect and use your personal data and where applicable this may include information related to your spouse/partner, directors, partners and owners (your “representatives”). This policy contains important information about the personal data we receive from you, create or obtain from other sources and explains how it will be used by us. It is important that you take the time to read this notice so that you understand how we will use your personal data and your rights in relation to your personal data.

If you have any questions about this policy, about how we process personal data or about your rights over your personal data, please contact us by email at info@withlevel.com or write to us at Level, The Columbus Building, London. E14 4HD

What is personal data?

Personal data is considered to be any information that either alone, or in combination with other information, would identify you as a living individual. For example, your name and date of birth.

Personal data that we collect about you

We will collect and use the following personal data about you and your representatives:

 Information you give us

  • This is information about you and your representatives that you give us by filling in our application form or by corresponding with us by telephone, e-mail or otherwise. The information you give us may include your and your representatives’ name, address, e-mail address and telephone number, identification documentation, financial and credit card information, employment history, health information, credit history, identification records, qualifications and vehicle or asset details.
  • You must ensure that in respect of any information you provide us with, which does not relate to you (for example, information about your representatives), you have obtained the necessary consent in order to disclose such information and provided the individual to whom the information relates with a copy of this notice.

Information we receive from other sources

  • Intermediaries – Your Solicitor will issue us with an application form and supporting documentation on your behalf by corresponding with us by telephone, e-mail or otherwise, for the purposes of entering in to and administering your agreement. The type of information collected may include; your personal details, contact details, relevant asset or policy details including your bank account number and sort code, identification documentation, ownership documentation and sensitive information such as any medical information disclosed to us, Your Solicitor is responsible for obtaining your approval to share your personal information with us in advance of submitting an application on your behalf
  • Financial/ Credit Information – We will use information provided by credit reference agencies when assessing your application for finance and to verify your or, if applicable, your representatives identity.  Such information may include some details about other credit you have taken out, any credit arrangements you have met or failed to meet, and any court judgments made against you.
  • Fraud Prevention Agencies – When verifying your identity as part of our application process, we may access information recorded by fraud prevention agencies within and outside the UK. This may include information about any criminal convictions and any allegations regarding criminal activity that relate to you.
  • Public databases – we may obtain information about individuals from public databases. We use reputable sources including but not limited to the electoral register, The Land Registry and Companies House. We employ appropriate measures to assure the quality of information which we collect.

Information we collect or generate about you and your representatives 

  • Website Usage Information – Our website uses Google Analytics to automatically gather certain statistical information such as the number and frequency of visitors and their IP addresses. This information is used as aggregated statistical information about users, providing usage by IP address. This information helps us to measure how individuals use the website and our services, so that we can continually improve them.
  • We may monitor and record communications with you (such as telephone conversations and emails) to resolve complaints, improve our service, fraud prevention and for training and quality assurance purposes.
  • We generate data for statistical analysis.

How we use your personal data

We gather information about you so that we can provide the services and products that you may request from us. Your personal data may be used by us in the following ways:

Credit Reference Agencies & Crime Prevention

If you make an application for credit, we will search your records at credit reference and fraud prevention agencies. Your personal data will be used;

  • to verify your identity as part of the account opening process for new customers;
  • for carrying out a credit check on you. We may carry out a search with a credit reference agency who will keep a record of our enquiry against your name and which may be linked to your representatives. We may also add to your record with the credit reference agencies, giving details of your agreement with us, any payments you make under it and any default or failure to keep to its terms. These records will remain on the credit reference agencies’ files for 6 years after our agreement with you is settled or terminated whether settled by you or by way of default. These credit reference agencies may create, or add to, their own record about you, details of our search and your application. This and other information about you and those with whom you are linked financially may be used to make credit decisions about you;
  • You can find further information about how credit reference agencies (CallCredit, Equifax and Experian) may process your personal data at experian.co.uk/crain
  • we may use credit scoring techniques and automated decision making systems to either fully or partially assess your information. These credit scoring techniques and automated decision making systems may take into account any previous applications for finance, defaults or existing debt. The results of this decision may decide whether we provide you with our services or not. If you disagree with the results of an automated decision, you can request a review of your application;
  • to allow us to detect and prevent fraudulent activity including sharing personal data with fraud prevention agencies; and
  • to allow us to detect and prevent money laundering activity or terrorist financing.
  • If you require details of the credit reference agencies and fraud prevention agencies we use, please contact us on info@withlevel.com

Products & Services

  • to provide you with information, products or services that you may request from us;
  • to carry out our obligations arising from any agreements you enter into with us;
  • to make payments;
  • to recover monies;
  • where we are permitted to do so, to send promotional information about our products and services via methods such as e-mail, post, telephone, etc.; and
  • to contact you via post, e-mail or telephone in relation to the administration of your account or to carry out quality control research.

Statistical Analysis

  • as part of our legal and regulatory obligations, to conduct statistical analysis in order to improve our credit risk profile, tackle fraud, and improve our credit decisions. This may include statistical analysis on your personal data even if your application is declined by us or you decide not to complete your application with us; and
  • in order to identify and offer you tailored products and services that are suitable for you and improve our service.

Legal basis for processing your personal data

We process your personal data pursuant to the following legal bases:

  • The use of your personal data as described is necessary for our legitimate business interests and in order to perform our contract with you for the relevant loan:
  • To take steps at your request prior to entering into it;
  • To decide whether to enter into it;
  • To manage and perform that contract;
  • To update our records;
  • To trace your whereabouts to contact you about your loan and recovering debt;
  • Enforcing the terms and conditions of any agreement we have with you;
  • The recovery of outstanding debts existing under an agreement with you; or
  • For statistical analysis to improve our products and services;
  • As necessary for our own legitimate interests or those of other persons and organisations, e.g.:
  • For good governance, accounting, and managing and auditing our business operations;
  • To search at credit reference agencies (CRA’s) at your home address;
  • To monitor emails, calls, other communications, and activities on your account;
  • To send you marketing communications
  • As necessary to comply with a legal obligation, e.g.:
  • When you exercise your rights under data protection law and make requests;
  • For compliance with legal and regulatory requirements;
  • For establishment and defence of legal rights;
  • For activities relating to the prevention, detection and investigation of crime; and
  • To verify your identity, make credit, fraud prevention and anti-money laundering checks;
  • Based on your consent, e.g.:
  • When you request us to disclose your personal data to other people;
  • To send you marketing communications where we’ve asked for your consent to do so.

You are free at any time to change your mind and withdraw your consent.  The consequence of this may be that we are unable to do certain things for you.

Sharing your personal data

We do not sell or share your data with third parties unless we have your consent to do so or it is necessary for the operation and management of our business and your account. For example, we may disclose your personal data to third party service providers in the circumstances described below:

  • to ensure the delivery or maintenance of products or services you have taken out with us;
  • to ensure the safety and security of our data; and
  • as part of our internal research and statistical analysis activity.

We will take steps to ensure that the personal data is accessed only by personnel that have a need to do so for the purposes described in this notice.

Your personal data may be shared with the following third parties:

  • Companies and other persons providing services to us;
  • to businesses who may process data on our behalf as part of a contract;
  • to third party agents or contractors (for example, the providers of our electronic data storage services) for the purposes of providing services to us;
  • to our professional advisers in order to enforce or apply the terms of use and other agreements you have with us;
  • to an insurer or insurers for administration;
  • to claims handlers, fraud prevention agencies, credit reference agencies and debt collection agencies when we open your loan account and periodically during your loan;
  • Government bodies and agencies in the UK and overseas (e.g. HMRC and with regulators e.g., the Financial Conduct Authority, the Information Commissioner’s Office);
  • to your solicitor or credit intermediary;
  • to any guarantor;
  • to any funder in order to enable funders to assess the value of our assets;
  • if we sell any of our business or assets, in which case we may disclose your personal data to the prospective buyer for due diligence purposes;
  • if we are acquired by a third party, in which case personal data held by us about you will be disclosed to the third party buyer;
  • Anyone else where we have your consent or as required by law.

These third parties will be subject to confidentiality requirements and they will only use your personal data as described in this privacy notice.

We may also share your personal data to the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation including but not limited to disclosures made to:

  • Credit agencies;
  • Companies House;
  • and to establish, exercise or defend our legal rights.

Transfer of personal data outside the European Economic Area

In providing services to you, from time to time, the data we collect from you may be transferred to, and stored at, or accessed from a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside of the EEA or for one of our suppliers.

Where we transfer your personal data outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

How long we keep your personal data

The following criteria are used to determine data retention periods for your personal data:

  • Retention in case of queries. We’ll retain your personal data as long as necessary to deal with your queries (e.g. if your application is unsuccessful);
  • Retention in case of claims. We’ll retain your personal data for as long as you might legally bring claims against us; and
  • Retention in accordance with legal and regulatory requirements. We’ll retain your personal data after your loan account has been closed or has otherwise come to an end based on our legal and regulatory requirements.

If you require details on how long we keep your personal data, please contact us on info@withlevel.com.

Your rights

You have a number of rights in relation to the personal data that we hold about you. These rights include:

  • The right to be informed about our processing of your personal data;
  • the right to object to our processing of your personal data where we process your personal data pursuant to our legitimate business interests. Please note that there may be circumstances where you object to our processing of your personal data but we may be legally entitled to refuse that request;
  • the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
  • the right to withdraw your consent to our processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so;
  • the right to request that we rectify your personal data if it is inaccurate or incomplete;
  • the right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;
  • the right to request that we restrict our processing of your personal data in certain circumstances. Please note that there may be circumstances where you ask us to restrict our processing of your personal data but we are legally entitled to refuse that request;
  • the right to object to any automated decision making (including profiling) which we conduct based on your personal data, which significantly affects you. Please note that there may be circumstances where you object to us conducting automated decision making but we are legally entitled to refuse that request;
  • the right to object to the processing of your personal data for direct marketing purposes; and
  • the right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us.

You can exercise your rights by contacting us using the details set out in the “Contact Us” section below.

You can find out more information about your rights by contacting the data protection regulator, the Information Commissioner, or by searching their website at https://ico.org.uk/.

Cookies

Cookies are small text files placed on your computer and are common throughout websites across the internet to help personalise your web experience. Some features on this site may not function if you do not allow cookies. We us them:

  • To collect anonymous information that will help us understand visitors’ browsing habits on our website, and allow us to improve our service;
  • To compile statistical reports on website activity, e.g. number of visitors and the pages they visit;
  • To define advertising on and off our website to certain users based on their browsing habits.

This Website may place and access certain Cookies on your computer. Level uses Cookies to improve your experience of using the Website. Level has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

  • All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
  • Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Level to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
  • This Website may place the following Cookies:
    • Type of CookiePurposeAnalytical/performance cookies – They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
    • Functionality cookies – These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
  • You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
  • It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
  • See our Cookies policy, for further information on Cookies and how we use them.

Links to third party websites

Our website may contain links to other websites. Our Privacy Policy does not apply to other websites so if you access links to other websites you should read that website`s privacy policy.

Changes to our privacy policy

Level reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.

Contact us

Level is the trading name of Integro Funding Limited, which is a limited company registered at 20-22 Wenlock Road, London, N1 7GU, company number 10467450.

Please contact us if you have any questions about our privacy policy or personal data we hold about you:

Write to us at our address: Level, The Columbus Building, London. E14 4HD

By telephone: 020 7205 2870; or

By e-mail: info@withlevel.com