Frasers Plus Credit Privacy Policy
Frasers Plus
Credit Privacy Policy
We view the security of our customers data as paramount. Any personal data about you and from which you can be identified is stored securely
and confidentially and is processed in accordance with applicable legislation (including the UK General Data Protection Regulation, the Data
Protection Act 2018, and the Privacy and Electronic Communications (EC Directive) Regulations 2003) and this Credit Privacy Policy, which sets
out what personal data we process when you interact with us and how we use your data in respect of the Frasers Plus credit product (“Frasers
Plus”).
We may change this Credit Privacy Policy from time to time – when we do, where appropriate, we will inform you via email.
Who we are
As set out in our Frasers Plus Credit Agreement Frasers Plus is operated by Frasers Group Financial Services Ltd, whose registered address is
Church Bridge House, Henry Street, Accrington, United Kingdom, BB5 4EE. Our company number is 00718151. We are the regulated lender for
Frasers Plus, which means we are authorised to make, or take assignments of, regulated consumer lending as part of our regular business
activities.
Frasers Group Financial Services Ltd. is the data controller in respect of personal data collected in connection with Frasers Plus. Our ICO
registration number is ZB553878. If you have any queries regarding our use of personal data or this Credit Privacy Policy, you can email
data.protection@frasers.group or write to Data Protection, Church Bridge House, Henry Street, Accrington, United Kingdom, BB5 4EE.
Frasers Group Financial Services Ltd. is also the data controller in respect of the Frasers Plus Loyalty Scheme. Please note that there is a separate
Loyalty Privacy Policy for the Frasers Plus Loyalty Scheme, which you can access here.
Frasers Plus Credit Privacy Policy
Data we may hold about you
In order to provide you with Frasers Plus, we will collect and process personal data about you, such as:
identification information such as your first name, last name, title, username (or similar identifier), date of birth, gender, job title and
visual identifiers (for example photos of you from your ID);
contact details such as your address, email address, and telephone number;
financial information and employment data such as salary, bank statements, account details and credit referencing information;
profile data such as your password, purchase information, your interests and preferences, your feedback and survey responses and social
media data (for example handles);
technical data such as your IP address, login data, time zone information, browser type and version, operating system and platform and
technology and devices used for accessing Frasers Plus;
usage data about how you use our products and services;
call data such as call logs and recordings; and
marketing and communications data.
We may also collect and process aggregated data, such as statistical or demographic data. For example, we may aggregate your usage data to
calculate the percentage of users accessing a specific app feature. We may use this data for the same purposes as set out below.
In some cases, the personal data we process is provided to us directly by you, for example, the personal data you share with us in your application
for Frasers Plus or when corresponding with us. We may also collect data from you indirectly, for example the technical data listed above as you
interact with the Frasers Plus website and app. In other cases, we also receive personal data about you from other sources - for example, from
third parties such as the credit reference agencies mentioned in 'How we might share your personal data' below, or from public sources such as
Companies House or the Electoral Register.
Frasers Plus Credit Privacy Policy
How we may use your personal data
We may use your personal data in the following ways:
to provide, run, administer and maintain the Frasers Plus product, your Frasers Plus account and any related products or services (e.g.
the Frasers Plus app);
to make assessments of your eligibility for Frasers Plus;
to make lending decisions in accordance with our internal policies, principles, and regulatory obligations;
to meet our legal, regulatory and compliance requirements (e.g. in relation to financial crime and anti-money laundering);
to process payments and handle transactions;
for debt tracing and recovery;
to detect and prevent fraudulent transactions and/or any other criminal activity (we may pass your details to a third party to carry out
these functions);
to provide information to, and receive information from, credit reference agencies and other third parties who help us to operate and
provide Frasers Plus;
to answer your questions, and deal with enquiries or complaints relating to Frasers Plus;
to communicate with you about your Frasers Plus account;
to tell you about Frasers Plus, similar products and services, or products and services that you ask us to send you information about, in
accordance with 'Marketing and promotional communications' below;
to undertake customer satisfaction surveys and other similar research;
Frasers Plus Credit Privacy Policy
to analyse and improve the Frasers Plus product, your Frasers Plus account and any related products or services (e.g. the Frasers Plus
app);
to support the sale, transfer or merger of part or all of our business or assets;
to manage our business;
where relevant, for the establishment, exercise or defence of legal claims; and
to keep our network safe and secure.
Automated decision-making
Please note that in some cases, we may undertake automated decision-making (including profiling), meaning that a decision about you is made
by automated means and without human involvement. We may make a decision either entirely or partially based on automated processes. This
automated decision-making occurs predominantly during the application process for Frasers Plus. We take into account the personal data you
provide on your application for Frasers Plus, information we receive from credit reference agencies ("CRAs") and fraud prevention agencies
("FPAs"), and other information we may hold about you (for example, any prior applications and your spending and payment history), and we
use automated means to:
assign you a score, based on our own internal criteria, which helps us to assess whether it is suitable for us to offer Frasers Plus to you
(for example, in determining your credit worthiness or affordability);
assess any risks of fraud and money laundering (for example, checking whether you are on any sanctions lists); and
make a decision as to whether to accept or decline your application for Frasers Plus.
Frasers Plus Credit Privacy Policy
We use automated decision-making processes because it helps us to:
make more informed, responsible and efficient decisions about lending;
grant you fair and unbiased treatment based on consistent and uniform criteria;
reduce the potential harm derived from human error, personal bias, discrimination and abuse of power; and
reduce the risk of you failing to meet your obligations under your agreement with us (for example, failing to meet payments).
Decisions made via automated decision-making may have legal or other significant effects on you for instance, a significant effect might be
that we may decline your application for Frasers Plus. Where you are subject to automated decision-making processes, you are entitled to
exercise specific rights aimed at preventing or limiting the potential effects of the automated decisions taken. For example, you have the right
to obtain an explanation about any decision taken as a result of automated decision-making, express your point of view or challenge such
decision, or request human intervention. Please contact us in accordance with 'How to contact us or complain' below if you want to find out
more about our automated decision-making.
Legal basis for using your personal data
We will only use your personal data when applicable legislation allows us to. We rely on the following lawful bases to process your personal
data:
where you have given us consent to use it – you are able to withdraw your consent at any time, by contacting us in accordance with 'How
to contact us or complain' below;
where it is necessary to perform an agreement we have entered into with you, or to take steps at your request prior to entering into an
agreement with you;
where necessary for compliance with our legal obligations; or
Frasers Plus Credit Privacy Policy
where it is necessary for our legitimate interests (or those of a third party), including in managing and operating our business, where
these are not overridden by your rights and interests.
How long we keep your personal data
We will not keep your personal data for any purpose(s) for longer than is necessary and we will only retain the relevant personal data that is
necessary in relation to the purpose.
When you apply for Frasers Plus:
if your application is successful, we will retain the personal data provided in your application, for registering an account for Frasers Plus,
and relating to your usage of Frasers Plus, for so long as that account remains in existence and for 7 years thereafter.
if your application is not successful, or you choose not to register an account for Frasers Plus, we will retain the personal data for 7 years.
In the case of any contact you may have with our customer services department, we will retain those details for as long as is necessary to resolve
your query and for 7 years after the query is closed.
If we are legally required or if it is reasonably necessary to meet regulatory requirements, resolve disputes, respond to any questions, complaints
or claims made by you or on your behalf, prevent fraud and abuse, keep records required by law or enforce our terms and conditions, we may
also retain some of your personal data for a limited period of time, even after you have closed your account.
We will retain your personal data for a short time beyond the specified retention period, to allow for information to be reviewed and any deletion
to take place.
Frasers Plus Credit Privacy Policy
How we might share your personal data
We may routinely share your personal data with other companies in the Frasers Group, which means the companies who are ultimately owned
or controlled by Frasers Group plc.
We may also share your personal data with carefully selected third parties who assist us in providing you with Frasers Plus. This includes the
following types of third party:
CRAs which perform credit and identity checks on you to assist us in processing your application for Frasers Plus including for purposes
such as assessing your creditworthiness, verifying the accuracy of the data you have provided to us, managing your account and tracing
and recovering debts;
FPAs which perform identity checks on you during your application for Frasers Plus and when you place new orders using your Frasers
Plus account;
Debt collection, purchasing and management agencies, which assist us in managing and recovering debts (for example if you default on
repayments);
Open Banking providers which will process your banking details as part the opening of your Frasers Plus account and ongoing account
management;
Communications and customer relationship management service providers which support our interactions with you (for example in
sending you service or marketing communications);
Analytics and research service providers who assist us in profiling, analysing and interpreting data;
Retailers who offer the Frasers Plus product or accept the Frasers Plus Loyalty Scheme ("Frasers Plus Retailers");
Our (and the Frasers Group's) technology and payments services providers;
Our (and the Frasers Group's) professional advisers, including, without limitation, our insurers; and
Frasers Plus Credit Privacy Policy
Our (and the Frasers Group's) suppliers, business partners and sub-contractors.
We will only share your personal data with third parties where it is necessary for them to provide us with the services we need.
In the event that we were to sell our business or assets, we may disclose your personal data to any prospective/actual purchaser and/or their
advisers.
We may disclose and exchange information with law enforcement agencies, government authorities and regulatory bodies to comply with our
legal and regulatory obligations.
We may also disclose your personal data where we are subject to a legal obligation to do so in connection with the prevention or detection of
crime, for the purpose of establishing, exercising or defending our legal rights, or where we consider that we receive a valid request for disclosure.
This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Please note that third party websites/providers have their own privacy policies and that we do not accept any responsibility or liability for these
policies. Please check these policies before you provide or submit any personal data to these websites/providers.
Where your personal data is held
Information may be held at our offices and in our IT systems and those of the Frasers Group as well as by its and our professional advisers, service
providers, suppliers, business partners and sub-contractors.
Some of these third parties may be based outside the UK or European Economic Area ("EEA"). For more information, including on how we
safeguard your personal information when this occurs, see below: ‘International transfers of your personal data’.
Frasers Plus Credit Privacy Policy
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully.
We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only
in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected
data security breach where we are legally required to do so.
Marketing and promotional communications
We and members of the Frasers Group and Frasers Plus Retailers may use your personal data to send you updates about each of our products
and services, including exclusive offers, promotions or new products and services for more information, including on how to opt out of
promotional communications, please see the Loyalty Privacy Policy here.
International transfers of your personal data
The personal data that we process may be transferred to, and stored outside, the UK or EEA. It may also be processed by staff operating outside
the UK or EEA who work for us or for one of our suppliers or third party providers. Where we do so, the third country’s data protection laws will
have been approved as adequate by the UK government/relevant UK authority or European Commission (as applicable), or other applicable
safeguards are in place. If you wish to receive a copy of these safeguards, please contact us in accordance with 'How to contact us or complain'
below.
Your rights
You have certain rights in relation to personal data we hold about you. Details of these rights are set out below. You can exercise these rights by
contacting us in accordance with ’How to contact us or complain’ below.
Frasers Plus Credit Privacy Policy
Right to Object to or
Restrict Processing
In some circumstances, you have the right to object to our processing of your personal data – e.g. if
we are processing your data on the basis of our legitimate interests and there are no compelling
legitimate grounds for our processing which override your rights and interests. You also have the
right to object to use of your personal data for direct marketing purposes (for more information, see
’Marketing and promotional communications’ above). If you have a complaint about how we have
handled your personal data, you may be able to ask us to restrict how we use your personal data
while your complaint is resolved.
Right to Withdraw
Consent
Where you have consented to us using your personal data, you can withdraw that consent at any
time.
Right of Erasure
In some circumstances you can ask us to erase your personal data e.g. if you withdraw your
consent, it is no longer necessary for us to use your personal data, you object to the use of your
personal data and we don’t have a good reason to continue to use it, or we haven’t handled your
personal data in accordance with our obligations.
Right of Access
You have the right, with some exceptions, to ask us to provide a copy of any personal data we hold
about you.
Right of Correction or
Completion
If the information we hold about you is inaccurate or incomplete, you can notify us and ask us to
correct or supplement it.
Right of Data Portability
You have the right to ask that we transfer the personal data you gave us to another organisation, or
to you, in certain circumstances.
Right not to be Subject to
Automated Decision-
making
You have the right not to be subject to an automated decision made by us which produces legal or
other significant effects on you. For more information, see 'Automated decision-making' above.
To exercise these rights, we need to be suitably satisfied of your identity and so may request you provide identification documents or confirm
other details we may hold about you (such as a recent delivery reference or address).
Frasers Plus Credit Privacy Policy
How to contact us or complain
If you have any queries or concerns regarding how we use your personal data, please email data.protection@frasers.group or alternatively write
to: Data Protection, Church Bridge House, Henry Street, Accrington, United Kingdom, BB5 4EE.
If you are not happy with our response, you can contact the Information Commissioners Office: https://ico.org.uk. The ICO’s address is
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, and its helpline number is 0303 123 1113.
This Credit Privacy Policy was last updated on 12 September 2023.