What this is
This notice sets out the ways in which Aura Finance Ltd (AFL) will collect and use your personal data in providing you with a bridging or short term loan secured against your property. It is important that you read and understand this document as this sets out how we store and process your personal data. It also gives detail on how and in what circumstances your data will be used and to which other third parties we will share the data in order to effect your loan application.
If you have any concerns or queries in regards to this, or the information set out within, please feel free to contact us to discuss these. You can contact our Data Protection Representative or Head of Compliance by the following methods:
In writing: 3rd Floor, Premiere House, Elstree Way, Borehamwood, Herts, WD6 1JH
By phone: 0333 123 4 556
Who we are
AFL is a bridging and short term loan provider which means we make loans to consumers which are secured by mortgage on the person’s home or other property. The loans we provide are generally short term in nature which means that they can last from 1 to 36 months in duration. Certain of these loans, especially those which are secured on a person’s home, require AFL to hold authorisation from, and be regulated by, the Financial Conduct Authority (FCA). Loans which are for business purposes, or provided to a business, or are on certain Buy to Let properties do not fall under FCA regulation.
The firm’s reference number with the FCA is 709675. You can check this, and obtain more detail on the company, on the Financial Services Register website: https://register.fca.org.uk/ or by contacting the FCA on 0800 111 6768.
AFL are also registered with the Information Commissioner’s Office under reference number: ZA036763. Further information on how the company uses and stores your data can be found on their register at: https://ico.org.uk/esdwebpages/search
The information that we use in order to provide our services is obtained from your financial advisor, data we request from you, and details obtained from Credit Reference and Fraud Prevention Agencies.
Why we collect your data
To enable AFL to assess an application for a loan we will require you to provide us with certain personal information necessary to understand:
– who we are making the loan to,
– your ability to afford to repay the loan over the term,
– other information which we would reasonably expect in order to aid us in fulfilling these requirements.
The requirements to ensure we have correctly and adequately identified each applicant for a loan is set out under money laundering legislation and regulation.
Under FCA regulation we have a responsibility to you directly, and to the market in general, to ensure that you will not be put into any financial or personal detriment by making repayment on the loan which we grant. To this end we have a duty to test the affordability of the loan against your current income and household expenditure.
Personal Data we will require
To meet the above we may need to see all or a selection of the following information:
- Your full name
- Your date of birth
- Your current and previous address(es)
- Your contact details
- Your income details, including payslips and bank account statements
- Your household expenditures
- Passport, or driver’s licence, or other form of photo identification
- Credit card, personal loan, or other loan or mortgage statements
- Other relevant details required to establish your identity
- Other relevant information pertinent to the application for a loan
This list of data items we may ask you for in order to provide finance is not exhaustive and will depend on your personal financial situation. You should be aware that the company may ask for additional details in order to enable us to fully assess your application. Any additional information will always be pertinent to your financial situation. Information that we will never ask for are details on:
- Your religious views
- Your sexual orientation
- Your trade union membership
- Your political views
What we do with your data
The primary reason that we collect your data is to enable us to make a decision on whether we are able to provide you with the finance you need and whether you will be able to repay based on the evidence you submit. Our decision to provide you with a loan is not guaranteed and will only be completed once we have received sufficient data, in our view, to enable us to objectively decide that you can afford the loan over its term.
All personal data that you submit will be stored to our company databases and will only be used in the provision of this particular loan product. We do not pass any of your information to any other external third parties for any form of marketing purposes. If this changes at any time in the future you will receive a written request from this firm to provide your explicit consent.
With whom do we share your data
Your data will be shared with other, external data processors to assist us in providing you with finance. These include:
- Credit Reference Agencies (CRAs)
- Fraud Prevention Agencies
- Our parent company, Enra Group Ltd
- Our regulator, the FCA
- Statutory Bodies on their lawful request, e.g. NCA, police forces
- External funders
Credit Reference Agencies
As well as the provision of your data to the above mentioned external agencies, AFL will also submit your data to a Credit Reference Agency (CRA) as part of the application process for the assessment of a loan.
Submission of your data will enable us to view your current credit profile giving details of your financial commitments held across the market. We use this information as part of our assessment of your application.
You should note that when we perform a search on your credit file a record of this search will not be displayed to any other firm that searches your profile and will only be visible to you.
Fraud Prevention Agencies
As part of the application process, and in our legitimate interest to prevent financial crime, AFL will use your personal data to ensure against fraud and money laundering. In order to do this we will submit your data to specific fraud and money laundering prevention agencies. Details of which agencies we use can be obtained from our Data Protection Representative at the above address.
We and the particular agencies may also enable law enforcement agencies, where there is a statutory requirement, to access and use your personal data to detect, investigate and prevent crime.
If we, or one of the mentioned agencies, determine that you pose a fraud or money laundering risk, we, and others, may refuse to provide the services and financing you have requested or may request.
A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing, or employment to you. If you have any questions about this, please contact us on the details provided.
These agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.
Your personal data may be submitted to a surveyor to carry out a valuation on your property. The data passed will only consist of sufficient information they require in order to carry out this specific function.
As part of the loan process, we will in certain circumstances pass your data to solicitors acting on behalf of the company. These details will only be shared to facilitate the completion of a loan and the management of the transfer of funds to that solicitor acting on your behalf.
AFL is a part of the Enra Group of companies. As a result, a number of the functions which are common to each firm is undertaken centrally by Enra. This will entail sharing your data with Enra for the purpose of maintaining and administering your loan contract as well as processing your data for internal statistical purposes only.
The FCA and other Statutory Bodies
Where the firm is regulated, we have an obligation to report certain personal data to the FCA, a statutory body set up under legislation. We have further requirements, where requested by other statutory bodies, such as the National Crime Agency, police forces, the Serious Fraud Office, etc. to provide specified personal data on their lawful request for information. This is done on a confidential basis and, through legislation, you will not be entitled to be informed of when this transfer of data has occurred. Details of what data we have submitted to these entities are also exempt from disclosure under a Subject Access Request.
Retention of your data
AFL will store your personal data only for as long as it is necessary for us to maintain the relationship that has been established through your application for a bridging or short term loan.
Where AFL provides credit to you, we will securely retain your personal details for at least the term of the credit agreement plus 7 years, and will update these details should you notify us of any material change during this period.
Should you redeem your loan before the end of the contractual term, we will retain your personal data for at least seven years from the date of redemption in order for us to meet our regulatory responsibilities.
In any instance where you ask us to cease processing your personal data prior to the completion of your application, AFL will retain your personal data for a period not greater than two years from the date of your request to cease processing your data in order that we meet our regulatory obligations. When your loan draws down we will be unable to facilitate any request to cease processing of your data until such time as the loan completes plus 7 years. Please con
Your personal data is protected by legal rights which includes your rights to:
- object to our processing of your data,
- request that your data is erased or corrected
- portability of your data, i.e. request that it be sent to another Data Controller
- request access to your personal data
Where you request AFL to cease processing your data prior to the assessment of your application for finance through AFL, this will affect our ability to assess your application and provide finance to you.
The right to your objection to our processing, or request erasure, of your data is subject to our regulatory and legislative responsibilities as well as to the correct maintenance of any contract that we may enter into for the provision of investment opportunities. This means that we have a legal necessity to retain your data while you have a loan underway with the company in order that we correctly manage the contract set out at the signing of your Mortgage Offer. We also must retain your data for a period of 6 years after the completion of any loans with the business to meet our regulatory obligations.
Where we have made an error on your data and you wish to submit a correction please contact us via the above methods.
The above contact details should also be used to request copy of all personal data we hold on you. We will endeavour to provide all data that we hold as soon as possible upon receipt of your request and will take no longer than 30 days to do so.
You have the right to request that data which we hold is passed to another Data Controller for their use on your behalf via a “machine readable” format. This can be requested from the Data Protection Representative of Aura.
You also have a right to complain to the Information Commissioner’s Office (ICO) which regulates the processing of personal data. AFL’s registration number with the ICO is ZA036763. The ICO can be contacted via the following methods:
Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
Telephone: 0303 123 1113
All Data that Aura collects is controlled and stored within the UK. We do not transfer data to any entity outside of the UK or the EEA. Where this does occur, we will inform you of the situation and seek your consent prior to the initiation of the transfer.
A ‘cookie’ is a piece of data that a website transfers to the internet browser on your computer’s hard disk, which lets the website “remember” who you are. It will usually contain a unique, randomly generated, number. Major commercial and business websites generally employ cookies. They cannot be used by themselves to identify you, and we will not attempt to use them for this purpose. You can delete cookies manually – if you wish to do so, please consult your browser help manual. (There are also websites that help you do this.) “Session cookies” stay in your browser only until you close it. “Persistent cookies” stay in your browser for longer – how long depends on the “lifetime” of the relevant cookie.
Use of ‘cookies’
We use session cookies to allow you to carry information across pages and avoid you having to re-type it. We may use persistent cookies so we can recognise your number (but not identify you further) when you return to our website, and, potentially, to enable us to note your interests, and arrange or edit content to match your interests, or those of borrowers generally, in a better way. Third parties may also serve cookies through this website. They may be used to put together statistics to help understand how people use the site, or to check whether, and how often, particular content is being viewed.
Some pages may contain these electronic markers to allow us to count up the people who have visited these pages. They collect limited information, including the time when the page was viewed, and the cookie number. We may also carry web beacons placed by third party advertisers in order to track a campaign’s effectiveness, but, again, these will not collect information that would allow you to be identified personally.