Privacy Policy

The Oakam website is brought to you by Oakam Limited, a company incorporated and registered in England and Wales with the company number 05878249 and it’s registered office at 3rd Floor, Moray House, 25-31 Great Titchfield Street, London, W1W 7PA.

In the event that we decide to change our policy, we will post these changes on this page so that you can be aware of what information we collect, how we use it and when we disclose it.

In this document all references to “we” or “us” refers to Oakam Limited; all references to “you” refer to you, the data subject.

At Oakam, we take your privacy very seriously. As such, we ask that you read this Privacy policy carefully as it contains important information about:

(a)        what personal data we may collect from you;

(b)        how we will use, store and protect your personal data;

(c)        with whom we may share personal data; and

(d)        your rights under relevant data protection laws.

It is important that you read this Privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy policy supplements the other notices and is not intended to override them.

This website contains hyperlinks to websites owned and operated by third parties. These third-party websites have their own privacy policies, including cookies, and we urge you to review them. They will govern the use of personal information you submit or are collected by cookies whilst visiting these websites. We do not accept any responsibility or liability for the privacy practices of such third-party websites and your use of such websites is at your own risk.

When you visit our website or The Oakam App, we may collect and process the following personal data about you:

• Technical data and user data, including standard internet log information and details of visitor behaviour patterns.
• Identity and contact data, including title, first name, maiden name, last name, username or similar identifier, address, email address, telephone number, marital status, date of birth and gender.
• Financial data and banking data including bank account, debit card, payments to other lenders and utilities providers, income and expenditure details you disclose to us and information about your credit history
• Before we provide services, goods or financing to you, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you.

We collect your personal data in a number of ways:

• Automatically: as you browse the Oakam website certain information relating to your browsing patterns and technical data about the equipment you are using to access the website is automatically collected using cookies and other similar technologies. Please see our Cookie policy here for further information.
• Directly: contact, financial and identity data directly provided by you when you fill in online forms or correspond with us in any way, for example:
  • various parts of our website rely on us being able to accurately identify you and require you to enter certain personal information, for example, when completing an application form. The data you enter when utilising these facilities will be used for those specified purposes and for assisting us in managing your enquiry only;
  • contacting us via the ‘contact us’ page;
  • requesting or consenting to marketing materials being sent to you; or providing us with feedback

Data provided by Credit Reference Agencies: In order to process your application, Oakam will supply your personal information 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. Your data will also be linked to the data of your spouse, any joint applicants or other financial associates (if applicable).

When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders. The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at:

• TransUnion: www.transunion.co.uk/crain
• Equifax: www.equifax.co.uk/crain
• Experian: www.experian.co.uk/crain

We may use your personal data for the following purposes:

• To provide the requested services to you;
• To find out things such as the number of visitors to the various parts of the site.
• In accordance with our legitimate interests (in circumstances where your interests and fundamental rights do not override our interests);
• To personalise your experience on the Oakam website;
• To provide customer service, including to respond to your enquiries and fulfil any of your requests for information;
• The personal data you have provided, we have collected from you, or we have received from third parties will be used to prevent fraud and money laundering, and to verify your identity.
• Details of the personal information that will be processed include, for example: name, address, date of birth, contact details, financial information, employment details, device identifiers including IP address and vehicle details.
• To send you important information regarding our services and/or other technical notices, updates, security alerts, and support and administrative messages; and
• As we believe to be necessary or appropriate:
  • in order to comply with a legal obligation. This applies where the processing is necessary for us to comply with the law;
  • to enforce or apply this Privacy policy; and
  • to protect our legitimate rights, privacy, property or safety, and/or those of a third party and your rights do not override those interests.
  • we and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

Under data protection laws, we must have a legal basis in order to process your personal data. The legal bases on which we may process your data are:

• Performance of a contract: where processing of your data is needed to perform a contract, we have with you or if you have requested we take specific steps before entering into a contract.
• Legal obligation: where processing of the data is required by law.
• Consent: where you have consented for us to process your personal data for one or more specific reasons.
• Legitimate interest: where the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data, which overrides those legitimate interests.
• We process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested.

As part of the processing of your personal data, decisions may be made by automated means. This means we may automatically decide that you pose a fraud or money laundering risk if our processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct, or is inconsistent with your previous submissions, or you appear to have deliberately hidden your true identity. You have rights in relation to automated decision making: if you want to know more please contact us using mydata@oakam.com.

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services or financing you have requested, or to employ you, or we may stop providing existing services to you.

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 above.

It is important to us that we only provide you with tailored offers and promotions for services which you may want or need. You will therefore only receive such offers from us in instances where you have expressed legitimate interest in our products or services, have consented to receive marketing, and have not at any point opted out from, receiving marketing communications from us.

Opting out from receiving marketing communications from us is easy and you may do so at any time by contacting us at unsubscribe@oakam.com. We will process your request to be opted-out of marketing within 30 days of receipt.

We will ensure that we obtain your consent before we share your personal data with any company outside of the Oakam group for marketing purposes.

Where you opt out of receiving these marketing communications, we may still process your personal data for other required purposes, as specified in section 3 above. This includes contacting you regarding an application you have started with us online or over the phone.

We may disclose your personal information to any member of our group, which means our group companies, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may disclose your personal information to third parties, including third parties located outside of the European Economic Area (EEA).

The third parties to which we may transfer your personal data include:

• In the event that we sell or buy any businesses or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use.
• To uphold our responsibilities to any credit reference agencies we report to.
• To our mailing and communications suppliers
• To market research and processing organisations to improve the level of service we are able to provide to our customers
• To an agent or agency acting on our behalf
• For the purposes of fulfilling our legitimate interests

The security of your data is important to us and we will, therefore, only transfer your data to such third parties in instances where:

• You have expressly consented to your data being shared with specific third parties;
• The third party needs to access the personal data for the purposes of providing any contracted services to you;
• The third party has agreed to comply with Oakam’s instructions, required data security standards, policies, and procedures and put adequate security measures in place;
• The transfer complies with any applicable cross border transfer restrictions and suitable safeguards have been put in place; and
• A fully executed written contract that contains suitable obligations and protections has been entered into between the parties.

Otherwise, unless you have given your consent, none of the data that we obtain will be provided to third party organisations in anything other than aggregate statistical form. It is not our policy to pass on personal information about our users to third parties unless you have given your consent.

As mentioned above, we will only transfer your data where suitable safeguards have been put in place. These safeguards are intended to ensure a similar degree of protection is afforded to your data wherever it may be transferred and include:

• Only transferring your personal data to countries which have been deemed to provide an adequate level of protection for personal data by the European Commission;
• Where your data will be transferred outside of the EEA, entering into specific contractual terms which have been approved by the European Commission and which give personal data the same protection as within the EEA; or
• Where your data will be transferred to the US, ensuring that the third party to which we are transferring your data is part of the Privacy Shield.
• Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.

For more information on the safeguards used by Oakam when transfers of personal data to third parties, please contact us at mydata@oakam.com

We will not retain your personal data for longer than is necessary for the purposes for which the personal data is processed. This means that your data will only be retained for as long as it is still required to provide you with services or is necessary for legal or regulatory reasons. When calculating the appropriate retention period for your data, we consider the nature and sensitivity of the data, the purposes for which we are processing the data, and any applicable statutory retention periods. Using these criteria, we regularly review the personal data which we hold and the purposes for which it is held and processed.

When we determine that personal data can no longer be retained (or where you request us to delete your data in accordance with your right to do so (please see section 8 below for more information)), we ensure that this data is securely deleted or destroyed.

However, please note that, in some circumstances we may decide to retain your personal data for research or statistical purposes and, in such circumstances, we will anonymise your data before retaining it.

Fraud prevention 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.

For more details about our retention periods, please contact us at mydata@oakam.com.

In order to protect your personal data, Oakam has appropriate organisational and technical security measures. We follow security procedures in the storage and disclosure of information that you have given to us, in order to prevent, as far as possible, any unauthorised access. These measures include ensuring our internal IT systems are suitably secure and implementing procedures to deal with any suspected data breach. However, due to the nature of the medium, we are unable to provide any guarantee that information stored by us will not be subject to unauthorised access and any transmission is at your own risk.

In the unlikely event of a data breach, we will take steps to mitigate any loss or destruction of data and, if required, will notify you and any applicable authority of such a breach.

You have certain rights in relation to the personal data we process and hold about you. These include:

• Right to rectification: you have the right to require us to correct any inaccuracies in your data.
• Right to erasure: you have the right to require us to delete your data, subject to certain legal requirements.
• Right to restriction of processing: you have the right to require us to restrict the way in which we process your personal data. You may wish to restrict processing if, for example:
  • you contest the accuracy of the data and wish to have it corrected;
  • you object to processing but we are required to retain the data for reasons of public interest; or
  • if you would prefer restriction to erasure.
• Right to data portability: you have the right to obtain from us easily and securely the personal data we hold on you for any purpose you see fit.
• Right to object to processing: you have the right to require us to stop processing your personal data should you wish the data to be retained but no longer processed.
• Right of access: you have the right to request access to personal data that we may process about you.
• Right to withdraw consent: you have the right at any time to withdraw consent allowing us to process your personal data.

If you would like more information or to exercise any of the above rights, please:

• Put your request in writing using any of the contact details below;
• Include proof of your identity (such as a copy of your driving licence or passport) and address (such as a recent utility or credit card bill); and
• Specify the right you wish to exercise.

We will respond to requests made by you within one month.

We will not charge a fee for you to exercise any of the rights listed above.

For more information about the cookies we use, please see our Cookies policy here

You should also be aware that you have the right to raise any concerns in relation to how we process your personal data to the Information Commissioner’s Office (ICO).

If you have any questions, comments or requests about this privacy policy please contact us.

We have appointed a data protection officer (DPO) who is responsible for dealing with any such concerns, in addition to overseeing questions in relation to this Privacy policy and handling requests in relation the exercise of your legal rights. If you have any concerns, questions, or requests, please contact the DPO using the details set out below.

Data Protection Officer:

Email address: privacy@oakam.com

Postal address:    

Oakam Ltd

Sunley House

Bedford Park

CROYDON

CR0 2AP