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Privacy Policy

Important - To register with us you must be 18 years of age or older and a resident of UK.

Our Privacy Policy

This privacy policy (policy) aims to give you information on how Gain Credit LLC and its affiliates may collect and process your personal data through your use of this website, including any data you may provide through this website as specified below.

For the purposes of this policy (policy), "you" or "your" means you as a user of the App Site or as a participant in the Services and/or a user of the Services Sites (as defined below). "We", "our" or "us" means GAIN Credit LLC of PO Box 10756, Leicester, LE3 4GX, and its affiliates.

Personal Data, Data Processor and Data Controller have the meanings given to such terms under the Data Protection Act 2018.

This policy, your credit agreement and any additional terms of use incorporated by reference into this policy, together (our Terms) apply to your use of:

Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it. We give you choices about the ways we use and share your Personal Data, and we'll respect the choices you make.

For the purpose of the General Data Protection Regulations (GDPR) and Data Protection Act 2018 (DPA), the data controller is GAIN Credit LLC. GAIN Credit LLC is a registered Data Controller and details of our notification to the regulator for data protection may be found in the Information Commissioner's Office Public Register of Data Controllers at www.ico.org.uk under registration number Z2752028.

Information we may collect from you

We may collect and process the following data about you:

  • Information you give us (Submitted information): You may give us information about you by filling in forms on the App Site and Our Sites. This includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, and when you report a problem with an App, our Services, or any of Our Sites. The information you give us may include your name, email address, mailing address, information about your transactions including loan balances, phone number, employer name, take-home pay, and banking information (such as bank sort code, debit card number and account number).
  • Information we collect about you and your device. Each time you visit one of Our Sites or use one of our Apps and/or Services we may automatically collect the following information:
  • technical information, including the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting (Device Information);
  • information about your computer, including your IP address, operating system and browser type (this is statistical data about browsing actions and patterns and is not in individually identifiable form); and automatic information obtained by using "cookies" when your browser accesses our Website and when you log-in (see the "Cookies" section below for more information);
  • details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access (Log Information).
  • Information we receive from other sources (Third Party Information). We work closely with third parties (including, for example, credit reference agencies, fraud prevention agencies, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
  • Unique application numbers: when you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
  • Contact with us: If you contact our customer services team or use our feedback form, We may keep a record of that correspondence or call.

Using your personal data

We may use your Personal Data for a number of purposes including:

  • in the normal course of our business to provide you with the Services or products you request, such as processing loan transactions and updating your account records;
  • to contact third parties, such as your employer, who you have nominated to verify information about yourself;
  • to enhance your experience of using our App and/or Our Sites or our Services;
  • for conducting statistical analysis;
  • to identify you when you contact us or visit our App Site or Our Sites;
  • to identify which of our products, or our partners' products, might interest you;
  • to prevent and detect fraud, this may involve the use of voice detection technology to analyse recordings of your telephone calls with us;
  • for other regulatory checks including credit assessment;
  • for editorial or feedback purposes for our advertisers;
  • aggregated information about users for editorial or feedback purposes for our advertisers.

Sharing your information

We may act as brokers as well as direct lenders, and our products and services may sometimes be provided in conjunction with our business partners. Thus, it may be necessary to disclose your information to those partners to provide you with the products or services you request. However, we will only disclose your information to such third parties where we have your express consent to do so via an 'opt in' mechanism on our website.

We may also share the Personal Data you submit with our associated group companies (which includes any company linked to us in some way by common ownership or management) for the purposes of: (a) the provision of products and service you request; (b) consumer profiling and market research; and (c) to contact you by post, phone or electronically about related products and services, offers and events, unless you opt out as described below (see the Marketing and Opt Out Rights section). A list of associated companies is available on request by contacting GAIN Credit LLC, or its related brands, directly via the contact details provided below.

If you consent via the opt in process, we may also share your Personal Data with selected third parties who may use it to contact you by post, telephone, email, SMS or other reasonable methods in relation to offers they feel might interest you, to seek your feedback, suggestions or opinions on current products, or for editorial, survey, research and product development purposes.

 

We may also share your Personal Data with third parties under the following circumstances:

  • with lenders, credit reference agencies, customer service providers and collection agencies. We have trusted relationships with these carefully selected third parties who perform services on our behalf. All service providers are bound by contract to maintain the security of your Personal Data. Credit reference agencies may add to their records about you, information about our search of their records and your application with us, and this will be seen by other organisations that make searches;
  • with a purchaser, in the event our business or substantially all of its assets are acquired by a third party (in which case Personal Data held about customers will be one of the transferred assets);
  • in order to enforce any of our terms and conditions;
  • with fraud prevention or law enforcement agencies, in the event false or inaccurate information is provided and fraud is identified. We and other organisations may also access and use this information to prevent fraud and money laundering, for example when checking details on applications for credit and credit related and other facilities; managing credit and credit related accounts or other facilities; recovering debt; checking details on proposals and claims for all types of insurance; and checking details of job applicants and employees. For further details of the relevant fraud prevention agencies please contact us as described at the end of this policy;
  • with individuals who you nominate as your referees to verify certain information that you provide to us;
  • if required or compelled to do so by any legal authority, as required by law or when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on us;
  • with other third party service providers, who act as agents to perform tasks on behalf of and under the instructions of GAIN Credit LLC. These service providers must agree to use Personal Data only for the purposes for which they have been engaged by us and must either: (1) Process it in a territory which the UK has determined provides an adequate level of protection for Personal Data; or (2) Implement appropriate safeguards to protect your Personal Data, including transferring it in accordance with an applicable transfer mechanism such as UK Standard Contractual Clauses.

The following list contains the names of third parties with whom we may share such information for purposes of providing you with alternative loan offers or other products that may be suitable for you:

Please note that for full details on how we may use your information to determine and/or provide provision of loan facilities you should read the Use of Information Statement contained in your pre-contractual loan documentation.

Credit Reference Agencies:

In order to process your application we will supply your Personal Data to credit reference agencies (CRAs) and they will give us information about you, such as about your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity.

We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations.

The identities of the CRAs, and the ways in which they use and share Personal Data, are explained in more detail at [http://www.callcredit.co.uk/crain and http://www.experian.co.uk/crain].

Information about third parties

We may also request that you provide details of individuals who are able to act as referees on your behalf by verifying some of the Personal Data you provide about yourself. The information we will request about these third parties will include their name, address and phone number.

Cookies used by Drafty and Third Parties

We may also request that you provide details of individuals who are able to act as referees on your behalf by verifying some of the Personal Data you provide about yourself. The information we will request about these third parties will include their name, address and phone number.

Marketing and opt-out rights

By visiting our App, Our Sites and/or the App Site through the express consent via an 'opt in' mechanism on our website, you understand and agree that we may contact you via the phone number or e-mail address you enter on your loan application to assist you with your loan or to discuss other products and services that GAIN Credit LLC may provide for you. You may opt-out of receiving these marketing communications from us or from our associated companies by responding to any of our e-mail communications with "remove" in the subject line or use the unsubscribe options provided in the email and SMS communications received by you or by sending us an e-mail to customercare@drafty.co.uk.

If you opt-out of our use of your Personal Data for marketing purposes, we will make reasonable efforts to honour such choice within 10 business days. We reserve the right to take reasonable steps to authenticate your identity with respect to any such request or other inquiry.

As noted above, if you consent to allow us to share your information with selected third parties, you may receive follow-up contact and offers from third party companies and, while we only work with selected partners, we are not responsible for the services or representations of these third parties. To opt-out of receiving further marketing emails, calls, or SMS messages from such third party, please contact the third party directly.

Automated decision making

 

Sometimes we use your Personal Data in automated processes to make decisions about you, such as credit scoring. We might also use automated processes to create a profile of you. We do this to help ensure decisions are made accurately, fairly and efficiently and to offer you products and services.

Underwriting:

We use automated decision making using your Personal Data to create a profile of you for credit scoring – a method which predicts your credit worthiness based on your financial profile.

To carry out credit scoring we use information you give to us, information we obtain from credit reference agencies, and details about how you have used other products and services you have with us. In some cases we will also use external data sources for credit scoring(refer to the Credit Reference Agencies section above). We analyse this information to identify a credit score based on how likely it is that debts will be re-paid.

We use credit scoring to make the following decisions about you: whether we enter into a contract to provide a product or service to you; whether to adjust products or services you have (such as an increasing or decreasing credit limits; to pre-approve any suitable products or services for you; and in some cases where we need to recover a debt from you.

Marketing:

We want you to get the most relevant information about products and services at the right time. The most effective way for us to do this is to use automated processes to create a profile of you for marketing. To carry out marketing profiling we use information you give to us, details about how you have used other products and services you have with us and any feedback you have given us, information we have obtained from credit reference agencies, Social networking platforms and information from other companies we are partnering with.

We use processes to analyse this information to decide what products and services to offer to you and to prioritise the marketing messages you receive by assessing your eligibility for those products and services; assessing how likely they are to be useful for you; and deciding how likely you are to respond.

Data Retention:

We keep the Personal Data of customers and visitors for a minimum of six years after closure of your account or from the date you last used one of our services. We may hold information relating to loan accounts falling under the non-personal information category for longer where necessary for active or potential legal proceedings, to resolve or defend claims, and for making remediation payments.

Access to your Personal Data

When we receive any request to access or update your Personal Data, we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information from fraud and identity compromises.

  • At any time you may review or update Personal Data that we hold about you, by reaching out to us through customercare@drafty.co.uk.
  • To obtain a copy of any information that is not provided on our website account section, you may send us a request at customercare@drafty.co.uk.

Data Portability

Where Personal Data is processed by us through electronic means and in a structured and commonly used format, you shall have the right to obtain a copy of such data in an electronic or structured format that is commonly used and allows for further use by you, the Data Subject. The exercise of this right shall primarily take into account the right of the Data Subject to have control over his or her Personal Data being processed based on consent or contract, for commercial purpose, or through automated means subject to data protection obligations under Data Protection Act 2018. For any further information please contact to customercare@drafty.co.uk.

Your privacy rights:

You have the right to withdraw your consent for our processing of your Personal Data, the right to object to how we use your Personal Data and the right to see what Personal Data we hold about you. In addition, you can ask us to correct inaccuracies, delete or restrict Personal Data subject to our legal and contractual obligations.

To make enquires for further information about exercising any of your rights in this Privacy Notice please contact our Data Protection Officer by email on customercare@drafty.co.uk or by post: Drafty, PO Box 10756, Leicester, LE3 4GX.

You can also make a complaint to the data protection supervisory authority, the Information Commissioner's Office, at www.ico.org.uk.

Use of site by children

We do not sell products or provide services for purchase by children aged less than 18, nor do we market to them by any means. We collect data about all users of and visitors to our website regardless of age, through cookies, and we anticipate that some of those users and visitors will be children. Such visitors including children may be able to visit other parts of the website and may be subjected to the available online financial promotions or marketing contents.

Security and retention of information

We are aware of the importance of the data we collect from you and therefore we use advanced technology to protect your information. We take reasonable precautions to protect Personal Data from loss, misuse and unauthorised access, disclosure, alteration and destruction.

For example, we store data in encrypted form on computers and control access via secure web pages. We also employ firewalls and other security technologies to protect our servers from external attack. In addition, we train our employees in the proper handling of Personal Data and when we use other companies to provide services for us, we require them to protect the confidentiality of Personal Data they receive.

When you enter certain more-sensitive information (such as your bank sort code or account number) on the application form, we encrypt that information using secure socket layer technology.

We only keep your Personal Data for as long as necessary(see the Data Retention section), for the purposes for which it was collected, to provide you with services and to conduct our legitimate business interests or where otherwise required by law. In addition, we take reasonable steps to ensure that the data we collect is relevant for its intended purposes, and is accurate, and up to date.

Blog

If you submit or create a blog on our App Site or Our Sites, you should be aware that any Personal Data you submit can be read, collected, or used by other users of these blogs, and could be used to send you unsolicited messages. We are not responsible for the Personal Data you choose to submit in these forums.

Customer Testimonials

We post customer testimonials, which may contain Personal Data, on the App Site, banners and/or Our Sites as well as some other websites with GAIN Credit LLC or its related brands' presence.

Third party links in our website

Our App, Our Sites and/or App Site may contain links to third party websites. If you follow a link to any of these third-party websites, please note that such websites have their own terms and privacy policies, and that we are not responsible or liable for any of the practices of these third-party sites.

International Data Transfers

Gain Credit LLC operates globally with affiliates and vendor partners including third countries, which means Personal Data may be stored and processed (for example stored in a data center) by us or our service providers for the provision of services relevant to you. By providing Personal Data for any of the purposes stated above, you acknowledge that your Personal Data may be transferred to or stored in third countries outside of UK and we will take necessary measures to safeguard Personal Data in accordance with the contractual obligations and data protection legislation applicable to the provision of services. Your Personal Data will only be transferred if we or our vendor partners:

  • Process it in a territory which the UK has determined provides an adequate level of protection for Personal Data; or
  • Implement appropriate safeguards to protect your Personal Data, including transferring it in accordance with an applicable transfer mechanism (such as UK Standard Contractual Clauses).

Please note that our affiliates Global Analytics India Private Limited (GAI), GAIN Credit Holdings, Inc and GAIN Credit, Inc also adhere to the above said principles.

Responsibilities

GAIN Credit LLC is committed to applying the GDPR/DPA Principles; Accountability for onward transfer; Security; Data Integrity and Purpose Limitation; Access; Recourse; Enforcement and Liability to all Personal Data. All employees of GAIN Credit LLC are required to comply with the GDPR and DPA. GAIN Credit LLC is potentially liable for onward transfers of Personal Data to our vendor partners existing in third countries outside of UK.

Changes to Privacy Policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App, Our Site, the App Site or the Services.

This policy was last updated on 25.02.2021

Contact Us

If you have any questions or concerns about the use of your Personal Data as described above, please contact us at Drafty, a trading name of GAIN Credit LLC, PO Box 10756, Leicester, LE3 4GX | Registered Address: 251 Little Falls Drive, Wilmington, DE 19808, USA|Registered in the State of Delaware, USA | Registration Number: 4124111 | Authorised and Regulated by the Financial Conduct Authority. Registration Number 689378 | ICO Registration Number : Z2752028 |You can contact us at 0203 695 8072 (Call charges apply. Standard charges from BT landlines, mobiles and other providers may vary) or email us at info@drafty.co.uk. | Copyright © GAIN Credit LLC

Drafty is an FCA-authorised provider of a Revolving Line of Credit with a credit limit of up to £3000, available to borrow as and when you need it (subject to affordability checks). You only pay interest on what you draw/use.

Representative Example: Assumed credit limit: £1200. Representative 96.2% APR (variable). Annual interest rate 69.4% (variable).

There is no set minimum or maximum repayment term, so long as the minimum monthly repayment sum is met, however, you may repay back early without any fees and save on interest.

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