2. About TotallyMoney
The website www.totallymoney.com (“Site”) and the TotallyMoney App (“App”) are owned and operated by TotallyMoney Limited trading as TotallyMoney (“we”, “ us” and “our”). We are an appointed representative of MI Money Limited which is authorised and regulated by the Financial Conduct Authority in respect of consumer credit related activities including the provision of credit information services (FCA FRN 511936).
Data protection law applies to our collection and use of personal information and TotallyMoney Limited is the controller for that personal information (ICO Registration Number Z1096594) of Churchill House, 142-146 Old Street, London, EC1V 9BW — details of our registration can be found online at the ICO website.
3. The information we collect about you
In order to provide our Services to you, we collect information about you from four main sources, as more fully described below:
(i) from you when you register;
(ii) from the credit reference agencies we use (for example to provide credit report and score data);
(iii) from our third party service providers and the Lenders we work with to receive eligibility data;
(iv) information about your visit, such as our analysis of how you behave on our Site.
4. About our services
We have two sets of services available through our Site: those you need to register for, and those you do not. If you register with us, you will create an account with TotallyMoney (“TotallyMoney Account ”) that will give you access to our “Account Services” — that is, access to a free credit report and credit score service (“Credit Report Service”), plus tailored information about your borrowing power and eligibility for Products (“Borrowing Power Service”). If you do not wish to register with us, you can still access our “Intelligent Alerts Service”, which allows you to check your eligibility for Products, compare Products and to be alerted on a monthly basis to changes in your eligibility for Products.
Personalisation is an important part of our Services. We may analyse and profile your information in order to tailor the information that we present to you, to improve our Services, and to determine the offers and communications that might be of interest to you (where applicable).
5. Intelligent Alerts Service
As part of the Intelligent Alerts Service, we provide certain credit product eligibility comparison services for Products, to let you compare Products and check your eligibility to apply. This will give you an understanding of the likelihood of your application for a Product being accepted. In order to provide the Intelligent Alerts Service, we collect and use certain information about you (“ personal information”) as further described below.
- You provide us with personal information (such as name, date of birth, email address, employment status, annual income, Product preferences, address, time at address and residential status) in order to check your eligibility for Products. We need this information to be able to provide the Intelligent Alerts Service to you including sending you the results of your eligibility check and your monthly eligibility update. If you do not provide this information you will not be able to benefit from the Intelligent Alerts Service.
- We use the personal information you provide to do a “soft search” or a “quotation search” on your credit file and compare your personal information with the acceptance criteria for the relevant Products. This involves us sharing your personal information with:
- Experian (our provider of pre-screening searches and eligibility checking services) in order to access your credit file, verify and validate the information you provide against publicly available databases and for fraud prevention purposes (please read Experian’s terms by clicking here); and
- the specific third party credit issuers that provide the Products (“ Lenders”) to check your eligibility for their Products (including whether or not you are an existing customer) and for fraud prevention purposes.
- Experian provides us with information about key elements of your credit file and the relevant Lenders send us the outcome of the Product eligibility checks. We use this information to provide you with your eligibility check results on the Site and we send the results to the email address provided to us by you.
- We will repeat the “soft search” and send the results to you by email or push notification (where you are using the App) every month for as long as you are subscribed to the Intelligent Alerts Service.
- You can unsubscribe from the Intelligent Alerts Service at any time by contacting us, by emailing us at email@example.com or by clicking the unsubscribe link in an email from us with your results.
- If you unsubscribe, we will no longer perform the monthly “soft searches” or email you with your results. You would need to resubmit your details on the Site in order to recommence the Intelligent Alerts Service.
The purposes of the processing described above is to provide the Intelligent Alerts Service to you. Our legal basis for processing is contractual necessity (to perform the Intelligent Alerts Service).
6. Account Services
When you register for a TotallyMoney Account:
- We ask you to give us certain personal information about you, your address and your finances (such as name, date of birth, employment status, annual income, Product preferences, address, time at address, residential status). We use this information to identify you and make our services more accurate.
- We also ask for your email address and a password to create your account. We need this information to be able to provide the TotallyMoney Account and in order for us to be able to provide the Account Services to you (as further described below).
- Callcredit Consumer Limited (“Callcredit”), who we work with to provide the Credit Report Service (as further described below), also asks you for certain personal information to verify your identity and authenticate you for the Credit Report Service (such as credit card details, information about when you last took out a credit card, any personal loans you have and/or mobile phone contracts). We do not see the information you provide (even though it is provided to Callcredit through a TotallyMoney branded interface as part of your TotallyMoney account registration), we only see the outcome of this authentication (e.g. authentication pass/failure).
- We will send you a welcome email with information about our Account Services and how to access them.
If you do not provide the information requested as part of the TotallyMoney Account registration process, you will not be able to benefit from the Credit Report Service.
It is vital that you keep your TotallyMoney Account information accurate and up to date as inaccurate personal information will produce inaccurate results. You can update your personal information at any time by accessing your TotallyMoney Account.
6.1 Borrowing Power Service
Once you have registered for a TotallyMoney Account, we will start to provide the Borrowing Power Service to you to help give you an understanding of how much you might be able to borrow based on your credit rating and the Products that you might be eligible for. We work with Experian and Lenders to provide the Borrowing Power Service to you.
- We use the personal information you provide as part of your TotallyMoney Account registration to do a “soft search” or a “quotation search” on your credit file and compare your personal information with the acceptance criteria for Products. This involves us sharing your personal information with:
- Experian (our provider of pre-screening searches and eligibility checking services) in order to access your credit file, verify and validate the information you provide against publicly available databases for the purposes of providing the Borrowing Power Service and for fraud prevention purposes (please read Experian’s terms by clicking here); and
- the specific third party credit issuers that provide the Products (“Lenders”) to check your eligibility for their Products (including whether or not you are an existing customer) and for fraud prevention purposes.
- Experian provides us with information about key elements of your credit file and the Lenders send us the outcome of the Product eligibility checks. We use this information to provide you with an indication of what you might be able to borrow and make this information available to you when you log in to your TotallyMoney Account and also via the email address provided to us by you or push notification (where you are using the App).
- We will repeat the “soft search” every month for as long as you are active on the Site. We will stop carrying out the “soft search” if you become “inactive” – i.e. stop logging into your TotallyMoney Account (we will carry out searches for up to twelve months after your last log in) - or if you close your TotallyMoney Account.
- We will alert you to the results of your monthly Borrowing Power “soft search” by email or push notification (where you are using our App) unless you unsubscribe from receiving such notifications. You can unsubscribe at any time – please see Paragraph 7 below but note that the searches will continue even if you unsubscribe from the alerts.
- We may analyse the data that you give us for the purpose of determining which products and services might be of interest to you.
- You can close your TotallyMoney Account at any time by contacting us, or by emailing firstname.lastname@example.org.
- As explained in clause 5.3 of our Terms and Conditions, we refresh the information every month to provide a better service to you.
6.2 Credit Report Services
Once you have registered for a TotallyMoney Account, provided that you complete Callcredit’s authentication process successfully and that your credit report can be found, we will start to provide the Credit Report Service to you to help give you an understanding of your credit report and score.
- We share the personal information you provide as part of your TotallyMoney Account registration with Callcredit in order to be able to provide the Credit Report Services.
- If you are authenticated for the Credit Report Services by Callcredit, Callcredit provides us with an unique ID that we use to request your credit report and score data every month as long as you are active on the Site. Your credit score data may be requested from Callcredit more frequently when you log into your TotallyMoney Account.
- We use the data provided to us by Callcredit to provide you with credit report and score data when you log into your TotallyMoney Account and to send an indication of updates to your credit report and score results to you by email or push notification (where you are using our App) every month.
- We also store certain credit report and score data to the extent necessary to provide the Credit Report Services to you (for example, in order to present a timeline of your credit score that loads quickly and is easy for you to use, we have to save information plotted on the timeline).
- We will request your credit report and score data from Callcredit and notify you that we have done so by email or push notification (where you are using our App) every month for as long as you are active on the Site. We will stop carrying out the “soft search” if you become “inactive” – i.e. stop logging into your TotallyMoney Account (we will carry out searches for up to twelve months after your last log in) - or if you close your TotallyMoney Account.
- You can close your TotallyMoney Account at any time by emailing email@example.com.
- As explained in clause 5.3 of our Terms and Conditions, we refresh the credit report information every month and the credit score information each time you log into your TotallyMoney Account to provide a better service to you.
We may use your personal information to send you information about promotions, and to tailor what we send to you, Products and services that may be of interest where we are legally permitted to do so or where you have consented to receiving direct marketing from us or a company similar to us (for example where you confirm to a third party that you consent to receiving marketing from companies that provide credit reporting and credit product services). We may occasionally have arrangements in place with third parties that have a direct relationship with you and they may send information to you about us and our services where they are legally permitted to do so. You may be contacted by post, email, App push notification, via social media, telephone or such other means as we regard as appropriate and legally permitted.
You may unsubscribe from receiving marketing communications at any time by contacting us, by emailing us at firstname.lastname@example.org or by clicking the unsubscribe link in any marketing email from us.
Please note that even if you do unsubscribe, we will continue to send you a monthly Credit Report Service email/push notification as part of the Credit Report Service, to record that we have accessed your credit report and score that month. We think it is important that we notify you for as long as we continue to access this information on your behalf. In the absence of misuse or your account being suspended / terminated by us, we will only stop checking your credit report and score and sending you notifications of such if you become “inactive” – i.e. stop logging into your TotallyMoney Account (we will carry out searches for up to twelve months after your last log in) - or if you close your TotallyMoney Account.
8. Correspondence with you
If you contact us, we may keep a record of that correspondence. For research purposes, from time to time, we may ask you to complete a survey, although you do not have to respond. We will send you emails/push notifications (as described above) as part of the Borrowing Power and Credit Score Services and we may also send you service messages in relation to your TotallyMoney account or our services from time to time (for example, to contact you about forgotten passwords or to notify you about changes to our services).
9. Website and app analytics
We capture details of your visits to the Site including the actual pages you visit, IP address (from which we may derive your location) and other communication data and details of the resources that you access. We also capture information about your computer or device including, where available, your operating system and browser type. This is used for system administration, to report aggregate information to our advertisers and to enable us to analyse behaviour and trends on the Site. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
10. To meet legal or regulatory requirements
We are required to comply with certain legal and regulatory requirements and we may process your personal information in order to comply with those requirements. Occasionally, we may be asked to provide certain information to regulators or law enforcement agencies and we will comply with these requests where legally required or permitted.
This processing is necessary for compliance with a legal obligation to which we or the regulator/law enforcement agency are subject.
11. Sharing your personal data with others
- We work with and are an appointed representative of MI Money Limited (authorised and regulated by the Financial Conduct Authority in respect of consumer credit related activities including the provision of credit information services (FCA FRN 511936)) to provide the Services to you and this involves us sharing your personal information with MI Money Limited.
- As described above, if you check your eligibility for a Product through our Site or register for a TotallyMoney Account, we will need to disclose the information you enter to the relevant third party Lenders or service providers (including Experian and Callcredit) in order to provide you with the services you have requested.
- The CRAs we work with (including Experian and Callcredit) and the Callcredit group of companies, may incorporate the information you provide when setting up your TotallyMoney Account and in the course of using the Services into their own databases, and for the purposes of operating as a credit reference agency. This will include using such data to assist with identity verification, prevention of fraud / money laundering, service delivery and process implementation.
- If you leave the Site in order to apply for a credit-based product, the Lender or service provider may use your personal information to perform an eligibility or full credit search with a credit reference agency for ID verification and validation purposes, credit assessment and fraud prevention activities. You should be asked to consent to this before your application is submitted.
- We may also disclose your personal information to any member of the Media Ingenuity Group (as defined in section 1159 of the UK Companies Act 2006) which means our subsidiaries, as well as our ultimate holding company and its subsidiaries.
- From time to time, we may consider corporate transactions such as a merger, acquisition, reorganisation, asset sale, or similar. In these instances, we may transfer or allow access to information to enable the assessment and undertaking of that transaction. If we are acquired in whole or part, either through a sale of shares or assets, customer personal data may be one of the assets transferred.
12. How and where we store your personal data
All of the information that you give us is stored on secure servers. We will periodically review this information to ensure that we do not keep it for any longer than is necessary.
The internet is not a secure medium. However, we have put in place various security procedures to protect your information. Firewalls are used to block unauthorised traffic to the servers – and the actual servers are located in a secure location which can only be accessed by authorised personnel. We use industry-standard encryption technology to ensure that all your personal and transactional information is encrypted before transmission to certain Lenders or third party service providers. Our security policies are in place to safeguard your privacy from unauthorised access or improper use – and we will continue to enhance our security as and when new technology becomes available.
13. Your rights
You have a right to:
- Access to your personal information (this may be subject to an administration fee of £10).
- Rectify your personal information if it is inaccurate or incomplete. Note that we cannot make changes to your credit report or score. Please see clause 6.5 of our Terms and Conditions for more information about what you can do if you believe your credit report or score is inaccurate.
- Obtain erasure of your personal information where there is no compelling reason for its continued processing in certain circumstances.
- Obtain restriction of processing of your personal information in certain circumstances.
- Object to processing of your personal information in certain circumstances.
- Receive your personal information data provided to us as a controller in a structured, commonly used and machine-readable format where our processing of the data is based on consent or necessity for performance of a contract to which the you are a party or to take steps at your request prior to entering into such a contract and the processing is carried out by automated means.
- Lodge a complaint with a supervisory authority.
- Object to and not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or significantly affects you.
Where we have said we process your personal information based on consent, individuals have a right to withdraw their consent at any time by contacting us or by emailing us at email@example.com.
We may obtain information about your general internet usage by using a cookie file which is stored on your browser – or the hard drive of your computer. Cookies contain information that is transferred to your hard drive. Some of these cookies are essential for the Site to operate. They help us to
(a) Improve our site and deliver a better and more personalised service;
(b) Estimate audience size and usage pattern;
(c) Store information about your preferences;
(d) Observe your browsing history;
(e) Recognise you when you return to the Site.
Cookies are widely used in order to make websites work, or run more efficiently, as well as to provide information to the owners of the Site.
You can find out even more about cookies at www.youronlinechoices.co.uk.
Details of Changes
New second sentence added to the first paragraph of section 7 to provide further clarification that third party arrangements may exist.
References to Media Ingenuity Limited changed to TotallyMoney Limited to reflect name change of company number 06205695.
Minor updates to Paragraphs 5, 6 and 7 including the addition of Experian’s terms and to clarify unsubscribe routes.