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PRIVACY NOTICE
UPDATED SEPTEMBER 2023
1. Introduction
1. In this Privacy Notice (referred to throughout as notice) we, our or us
refers to NewDay Ltd, its parent company NewDay Cards Ltd and any other
companies in the group to which they belong (referred to throughout this
notice as the NewDay Group). You or your refers to anyone whose personal
data we process. Reference to the retailer is to the retailer whose name
appears on the front of your card or loan documentation or through whom
you took out your NewDay credit product and references to the retailer
group refer to any company in the group to which the retailer belongs.
The retailer cards and loans are issued and administered by NewDay Ltd.
2. Details of the products offered by the NewDay Group to whom this notice
applies can be found on our website newday.co.uk/who-we-are/brands and
newday.co.uk/what-we-do/products. We may change this notice from time to
time and we will put any changes on our website www.newday.co.uk and,
where appropriate, changes will be notified to you by email or by post.
Please check our website frequently to see any updates or changes to our
notice.
3. This notice sets out how we will use and look after your personal
information and how we will share personal data with the retailer and
the retailer group. The retailer may also hold personal data where the
retailer processes your personal data for their own purposes. In this
case, the retailer will also provide you with a separate privacy notice.
If you are an additional cardholder, please see section 18 of this
notice, which explains how we use your personal data and the sections of
this notice that are applicable to you.
1. This notice covers the following:
1. Introduction
2. Whom should I contact if I have questions about this notice?
3. What are personal data and special categories of personal data?
4. Where do we obtain your personal data from?
5. What personal data do we use and why?
6. What personal data do we share with third parties and why?
7. What personal data do we share with CRAs and why?
8. What is the legal basis that permits us to use your personal
data?
9. What are the consequences of processing your personal data for
fraud prevention or anti-money laundering purposes?
10. What happens if you do not provide information that we request?
11. How and why do we grant third party providers access to your
online servicing account?
12. How long do we retain your personal data for?
13. What measures do we have in place to safeguard your personal
data?
14. When do we transfer your personal data overseas?
15. How do I find out about cookies?
16. Why do we use credit scoring and automated decision making as
part of your application?
17. How do we use your personal data for profiling?
18. How do we use your personal data if you are an additional
cardholder?
19. What rights do you have in relation to your personal data?
20. Your marketing preferences
21. Why do we need to record phone calls with you?
4. The table at the end of this notice provides an overview of the personal
data that we collect, the purposes for which we use that personal data,
the legal basis which permits us to use your personal data and the
rights that you have in relation to your personal data.
2. Whom should I contact if I have questions about this notice?
1. Should you wish to contact us about any aspect of this notice you can
contact our data protection officer using the following email address
dpofficer@newday.co.uk. Details of the retailer's data protection
officer can be found in the retailer's privacy notice or on their
website. If you are unable to find these details please contact our data
protection officer using the email address above.
2. NewDay Ltd and NewDay Cards Ltd are registered with the UK Information
Commissioner's Office (referred to throughout this notice as ICO).
NewDay Ltd's registration number is Z272680X and NewDay Cards Ltd's
registration number is Z5599433.
3. If you are unhappy with the way in which we are processing your personal
data you have the right to raise a complaint directly with the ICO.
Their contact details are Information Commissioner's Office, Wycliffe
House, Water Lane, Wilmslow, Cheshire, SK9 5AF. You can also call them
on 0303 123 1113 or email them on icocasework@ico.org.uk.
4. For more information about credit reference agencies (referred to
throughout this notice as CRAs) and how they use your personal data
please read the Credit Reference Agency Information Notice (CRAIN)).
CRAIN covers the activities of Experian, Equifax and TransUnion. We also
use credit reference services provided by Crediva. You can find a copy
of Crediva's privacy notice here. For a hard copy of this notice please
call Customer Services (see section 20.2).
5. For more information about fraud prevention agencies (referred to
throughout this notice as FPAs) and how they use your personal data
please contact us by calling our Compliance Team on 0371 522 5146.
3. What are personal data and special categories of personal data?
1. Personal data is any information that tells us something about you. This
could include information such as name, contact details, date of birth,
medical information and bank account details.
2. Special category personal data is any information relating to your
ethnic or racial origin, political opinions, religious or philosophical
beliefs, trade union membership, biometric data used to uniquely
identify you, health data or your sexual life. This personal data is
more sensitive and we need to have further justifications for
collecting, storing and using this type of personal data. There are also
additional restrictions on the circumstances in which we are permitted
to collect and use criminal conviction data
4. Where do we obtain your personal data from?
1. We get personal data about you from a number of sources as set out
below:
1. Personal data you provide when you request a quote directly from us
or via a price comparison, aggregator or similar website or if you
apply to us for a card and/or one of our products;
2. Personal data the retailer gives to us (a) in order to send you
marketing (where you have provided the retailer with your consent to
use your personal data for this purpose); (b) that the retailer
holds about you to inform our decision about your quote, application
or account and (c) about your spending habits when you use your card
and/or product;
3. Personal data you give to us in emails, letters, via online
servicing (including via chat and chatbots), during phone calls
(including any phone numbers that you use to contact us on) and when
registering for services such as our account management services or
Credit Score services;
4. Personal data we obtain about the IP address, operating system,
devices and browser that you use, including the location of any
devices used by you;
5. Personal data we obtain about you from the software we use to
prevent fraud when transactions are made using your account, or
attempts are made to log onto your online account manager or your
online banking app;
6. Personal data you give when you participate in surveys, promotions
or competitions;
7. Personal data we receive when making a decision about your quote,
application or account, including personal data we receive from
enquiries and searches made at CRAs and FPAs, from the retailers, or
from publicly available sources, for example the electoral roll;
8. Personal data we continue to exchange about you with CRAs on an
ongoing basis. For more information about the information that we
share with CRAs and how CRAs use your personal data in this manner
please see Section 7.4 or read the (Credit Reference Agency
Information Notice);
9. Personal data we have about any account you have with us including
details of transactions and payments;
10. Personal data we collect using analytics tools to track website page
content and click/touch, movement, scroll, and keystroke activity;
and/or
11. Personal data from card insurers or other organisations that you use
to search for credit products, including price comparison,
aggregator or similar websites that you visited before clicking
through to any of our websites.
12. Personal data we get through open banking services. This involves us
accessing account information that is held by other financial
institutions, such as your bank account statements. We get open
banking information through third party service providers. We refer
to this information as “open banking data”. For more information
about how we use open banking data please see Section 16.4
5. What personal data do we use and why?
1. We are a controller for the personal data that we obtain when providing
your card and/or product.
2. We hold and use the following personal data about you:
1. Personal data such as your name, address, address history, phone
numbers, email address, date of birth, passport information, driving
licence information employment details, identifiers assigned to your
computer or other internet connected device including your Internet
Protocol (IP) address, browser type, device data (which includes
information about the type of device you use, approximate location
and the specific device ID that is linked to the devices that you use
to access our services), behavioural biometric data (which includes
how you hold your device, your key strokes and mouse movements) and
financial information such as your bank account details, income and
expenditure and other information necessary to assess your financial
status. We use this information in order to verify your identity,
operate your account and for the purposes of preventing fraud and
money laundering;
2. Personal data relating to your demographic (which can include
information such as age, gender, place of residence, and can include
socio-economic factors such as occupation, family status, or income),
lifestyle, how you use your card and/or product and consumption
habits for example how you use your card and/or product. We use this
information to improve our card and/or products;
3. Personal data relating to any additional cardholders or financial
associates on or linked to your account. A “financial associate” is
someone with whom you have a personal relationship that creates a
joint financial unit in a similar way to a married couple. You will
have been living at the same address at the time. It is not intended
to include temporary arrangements such as students or rented flat
sharers or business relationships. CRAs may link together the records
of people that are part of a financial unit. They may do this when
people are known to be linked, such as being married or have jointly
applied for credit or have joint accounts. They may also link people
together if they, themselves, state that they are financially linked.
For more information about how CRAs use your personal data in this
manner please read the (Credit Reference Agency Information Notice);
4. Personal data that we obtain when you use any of our services,
including details of other services you have through us, such as
Credit Score or our eligibility checking services you have subscribed
to, or any card insurance provided to you by any other third party;
5. Any other personal data we need to operate your account, make
decisions about you or fulfil our legal or regulatory obligations.
3. In addition to the purposes stated above, we use the personal data we
hold for the following purposes:
1. To make credit decisions about you, assess lending risks and to
validate the details that you have provided to us;
2. To operate and manage your account, any application(s), any
agreement(s) or handle any correspondence you may have with us and
to conduct financial reviews (for example assessing your eligibility
for credit line increases, balance transfer offers, money transfer
offers or to monitor your account for fraud);
3. To enable us to perform other administrative and operational
purposes including the testing of systems, auditing and other
compliance related activities to ensure that we are complying with
our legal and regulatory obligations;
4. To monitor and analyse our business, including customer and declines
modelling and statistical trend and transactional analysis, to
identify, develop or improve products that may be of interest to
you, and to carry out market research;
5. To provide you with cards, products and services and tell you about
changes to these products and services;
6. To send you marketing in accordance with the provisions of Section
20;
7. To trace your whereabouts in the event we are unable to contact you
in relation to the products or services we provide to you;
8. To recover any debt you owe us;
9. To provide information on an anonymised basis to independent
external bodies such as government departments and agencies,
universities and similar to carry out research;
10. To comply with our legal and regulatory obligations and to identify,
prevent, detect or tackle fraud, money laundering, terrorism and
other crimes; and/or
11. To create anonymised data sets that can be used for big data
analytics by ourselves and third parties. For example, we might
create an anonymised dataset that shows in which shops on the high
street customers have spent money in the last 12 months.
4. We and the retailer, or members of either group, may send you
information directly in the form of service messages related to your
card and/or product where this relates to features or benefits of your
card and/or product for example, messages containing details of your
loyalty points. We want to make sure that we provide excellent customer
service and we use various means of communication to do this including
phone, post, email, push notifications and SMS.
5. If NewDay receives any funds from a third party which have been
incorrectly attributed or applied to your account, NewDay has a
regulatory obligation, upon request, to provide all your available
relevant information (including personal information such as your name
and contact details) to the third party's payment service provider (for
example their bank) to assist them with recovering such funds. If there
is an incorrect payment and the third party's payment service provider
is not able to recover the funds, the payment service provider may share
your information directly with the third party to enable them to recover
the funds.
6. When we are managing your account it is not our intention to routinely
process special categories of personal data. However, in certain
circumstances, (for example if you are unable to make re-payments to
your account or if you are incapacitated) we and the retailer may be
provided with special categories of personal data about your health or
medical information which we will hold and process to operate and deal
with your account. Additionally, where we receive open banking data
about you, this may contain information which is special category data.
For example, if we obtain bank statement information, this could include
details about payments made to medical service providers, which may tell
us something about your health. We never use health data or any other
type of special category data as part of our credit assessment (except
as part of a general assessment of the amount of your expenditure) and
we take steps to delete such data promptly if we receive it.
6. What personal data do we share with third parties and why?
1. We will keep your personal data confidential and only share it with
other third parties and organisations including the retailer for the
purposes explained below:
1. With any third parties who carry out services on our behalf to help
us operate our business, to provide services, to collect payment or
to recover debts. All these third parties have a contract with us
and have agreed to keep your personal data confidential and secure
and only to use it for the purposes that we allow.
2. With any person working within the NewDay Group or the retailer
group to enable us to perform our obligations in relation to the
provision of the services or products to you;
3. With any price comparison, aggregator or similar website that you
visit before clicking through to any of our websites. This personal
data will be shared regardless of whether or not you provided any
price comparison, aggregator or similar website that you visit (or
visited before clicking through to our website) with any personal
data at that time. We use the personal data provided to us via this
route to determine any payments due to such price comparison,
aggregator or similar website and assess your eligibility for any
NewDay products and/or services that you have applied for or have
agreed to receive marketing for. The personal data that we share
with such sites for this purpose is anonymised. Please note that you
can withdraw your consent to receive marketing from us at any time
by contacting Customer Services, using the unsubscribe link in any
email we send you or on your online account management page. Please
see Section 17 for more information about how we use your personal
data for profiling, Section 19 about the right to object to the
processing of your personal data and Section 20 about where we rely
on your consent to process your personal data;
4. With any firm, organisation or person together with whom we provide
products and services for example where we are providing a card
and/or product to you on behalf of a retailer. Where this is the
case, we share your information with the retailer so that we and the
retailer can assess the suitability and success of the products and
services that we provide, to enable the retailer to carry out its
own internal analysis and research and so that the retailer can send
you marketing communications (where you have consented to receiving
such communications). When we share your personal data with such
parties they will also be a controller for the personal data they
process. You should therefore read their privacy notices very
carefully to understand how they process your information;
5. With any payment system provider we may use to enable us to process
payments in relation to the services and/or products provided to
you;
6. With any firm that provides analytical, market research or similar
services to us;
7. With any insurers with whom you have any policy related to your card
and/or product so that they may administer your policy;
8. With your close relative, carer or helper, where you are unable to
handle your own affairs because of mental capacity, ill health or
other similar issues and we have been provided with authority to
disclose your personal data;
9. With any third party you have authorised to talk to us about your
account (which could include additional cardholders whom you have
added to your account or Debt Management Companies);
10. With any regulators, including the Financial Conduct Authority
(referred to throughout this notice as FCA), the ICO, the Financial
Ombudsman Service and other authorities including law enforcement
agencies and tax authorities, (including those overseas), where we
are required to disclose any personal data in order to comply with
our legal or regulatory obligations;
11. With any third parties or authorities including any CRAs and/or FPAs
for the purposes of undertaking checks for preventing or detecting
fraud and money laundering, or crime or to verify your identity or
to rectify any inaccurate personal data. When personal data is
shared with a CRA and/or FPA, the CRA and/or FPA may share your
personal data with other third parties (including law enforcement
agencies) for the purposes set out in the Credit Reference Agency
Information Notice and as described in Crediva's privacy notice. We
and FPAs may also enable law enforcement agencies to access and use
your personal data to detect, investigate and prevent crime;
12. With Mastercard Europe SA for the purposes of providing us with
advisory consulting services, managed services and/or data
analytical services;
13. With social media sites and digital advertising networks (for
example Google) for online targeted marketing as well as broadcast
channels (for example TV) for targeted marketing; Please see Section
17 for more information about how we use your personal data for
profiling, Section 19 about the right to object to the processing of
your personal data and Section 20 about where we rely on your
consent to process your personal data;
14. With any potential buyer, transferee, or merger partner and their
advisers in relation to any business transfer or re-organisation if
we decide to sell, transfer or merge part or all of our business or
assets, or any associated rights or interests or to acquire another
business. If we disclose your personal data for this purpose, we
will ensure that your personal data is kept confidential and only
used it in relation to the possible transaction(s). If the
transaction(s) go ahead, the purchaser, transferee or merger partner
may use your personal data in the same way as set out in this notice
or provide you with a new privacy notice explaining how your
personal data will be used by them;
15. With any debt purchaser in the event that we sell your debt. If we
disclose your personal data for this purpose, we will enter into a
contract with the third party debt purchaser requiring them to keep
your personal data confidential and process it in accordance with
the terms of this notice. Following the sale of your debt, the debt
purchaser will become a controller of your personal data and you can
request information from them detailing how your personal data will
subsequently be used. On the sale of your debt you will be provided
with the debt purchaser's contact details as part of our other
regulatory obligations; and
16. Where we have acquired your account from another creditor, with the
previous creditor for administrative, regulatory and legal purposes
and to help us deal with any complaints or other issues relating to
your account.
7. What personal data do we share with CRAs and why?
1. In order to process your quote or application (which includes applying
for a balance transfer or a money transfer), we will perform credit and
identity checks on you with one or more CRAs. Where you take financial
services from us, we may also make periodic searches at CRAs to manage
your account with us. Where you have been declined for a credit product
and have decided to appeal the decision, we will perform another search
with certain CRAs. A "soft search" allows us to make a check on your
credit file and will leave a footprint so that you can see that we made
the check, but the search will not show up to other lenders and will not
affect your credit rating. We use soft searches when we carry out
eligibility checks, in order to provide quotes and where you have
appealed a decline decision. If you make an application for one of our
products, we perform a "hard search" with certain CRAs. These searches
are visible to other lenders and may affect your credit rating.
2. To do this, we will supply your personal data to CRAs and they will give
us information about you. This will include information from your credit
application and about your financial situation and financial history.
CRAs will supply to us both public (including the electoral register)
and shared credit, financial situation and financial history information
and fraud prevention information.
3. We will use this personal data to:
1. Assess your creditworthiness and whether you can afford to take the
product;
2. Verify the accuracy of the data you have provided to us;
3. Where you are applying for a balance transfer, to check whether the
account from which the balance is transferring is registered to the
same address as the address that you have provided to us;
4. Prevent criminal activity, fraud and money laundering;
5. Manage your account(s);
6. Trace and recover debts; and
7. Ensure any offers provided to you are appropriate to your
circumstances.
4. We will continue to exchange personal data about you with CRAs while you
have a relationship with us. We will also inform some CRAs about your
settled accounts. If you borrow and do not repay in full and on time,
then CRAs will record the outstanding debt. This information may be
supplied to other organisations by CRAs.
5. When CRAs receive a search from us they will place a search footprint on
your credit file that may be seen by other lenders.
6. If you are making a joint application, or tell us that you have a spouse
or financial associate, we will link your records together, so you
should make sure you discuss this with them, and share with them this
information, before lodging the application. The CRAs we share data with
will also link your records together and these links will remain on your
and their files until such time as you or your partner successfully
files for a disassociation with the CRAs to break that link.
7. The identities of the CRAs, their role also as fraud prevention
agencies, the data they hold, the ways in which they use and share
personal data, data retention periods and your data protection rights
with the CRAs are explained in more detail:
1. In relation to TransUnion, Equifax and Experian: in their Credit
Reference Agency Information Notice at
http://www.experian.co.uk/crain/index.html. CRAIN is also accessible
from each of the three CRAs - clicking on any of these three links
will also take you to the same CRAIN document: TransUnion
www.transunion.co.uk/crain; Equifax www.equifax.co.uk/crain; Experian
www.experian.co.uk/crain.
2. In relation to Crediva in their Privacy Notice at
https://www.crediva.co.uk/crediva-processing-notice.
8. What is the legal basis that permits us to use your personal data?
1. We are only permitted to use your personal data and special categories
of personal data if we have a legal basis for doing so as set out under
data protection legislation. We rely on the following legal bases to use
your personal data:
1. Where we have your consent (Consent);
2. Where we need information to enter into a contract, or perform the
contract we have entered into, with you (Contractual Performance);
3. Where we need to comply with a legal or regulatory obligation (Legal
Obligation); or
4. Where it is necessary for our legitimate interests (or those of a
third party) and your interests and fundamental rights do not
override those interests (Legitimate Interest);
2. In more limited circumstances we may also rely on the following legal
bases:
1. Where we need to protect your interests (or someone else's interests)
(Vital Interest); or
2. Where it is needed in the public interest or for official purposes
(Public Task).
3. When we and FPAs process your personal data, we do so on the basis that
we have a legitimate interest in preventing fraud and money laundering,
and to verify your identity, in order to protect our business and to
comply with laws that apply to us.
4. The table at the end of this notice provides more detail about the
personal data that we use, the legal basis that we rely on in each case
and your rights.
5. Some information is classified as special categories of personal data
under data protection legislation. We may process special categories of
personal information and criminal conviction information in the
following circumstances:
1. In limited circumstances with your explicit consent, in which case we
will explain the purpose for which the information will be used at
the point where we ask for your consent; and
2. We will use information about your physical and mental health or
disability status to comply with our legal obligations, including to
ensure we are complying with our obligations to treat you fairly and
to assess your ability to repay your debt.
3. We will use behavioural biometric data to help us to confirm your
identity when you log into your online account manager or your online
banking app. This is necessary to prevent or detect crime.
9. What are the consequences of processing your personal data for fraud
prevention or anti-money laundering purposes?
1. If we, or a FPA, determine that you pose a fraud or money laundering
risk, we may refuse to provide a card and/or product to you, or we may
stop providing existing products to you.
2. A record of any fraud or money laundering risk will be retained by the
FPAs, and may result in others refusing to provide services, financing
or employment to you. If you have any questions about this, please
contact us by calling our Compliance Team on 0371 522 5146.
10. What happens if you do not provide information that we request?
1. We need some of your personal data in order to perform our contract with
you. For example, we need to know your address and phone number in order
to operate your account. We also need some information so that we can
comply with our legal obligations. For example, we need to know your
credit history so we can assess your ability to repay the balance on
your card and/or product to ensure that we are lending responsibly.
2. Where personal data is needed for these purposes, if you do not provide
it we will not be able to perform our contract with you and may not be
able to offer you a card and/or product. If you do not provide the
requested information, we may continue to process your personal data for
other purposes as set out in this notice.
11. How and why do we grant third party providers (TPP) access to your online
servicing account?
1. A TPP is a third party service provider that is authorised or registered
with the Financial Conduct Authority or another European Economic Area
regulator or otherwise permitted by law to carry on certain activities
on your instruction. These include:
1. accessing information about your account held with us if it is
accessible online; and
2. initiating payments from your account held with us if it is
accessible online.
2. If you choose to use a TPP, please ensure you understand how their
services work, such as how they access your account with us and how they
will protect your information including your personal data. Please also
be aware that:
1. If you use a TPP, the terms of your card and/or product will still
apply.
2. If a TPP is only asking for information about your account (and is
not initiating a payment from your account with us), we will assume
you have given your consent to us providing the information to that
particular TPP and we will provide the information immediately.
3. If the TPP is a card issuer who asks us to confirm whether you have
sufficient credit for it to initiate a card payment from your
account, we will only do so if you have given us your explicit
consent to provide information to that particular TPP.
4. Although you must not, generally, give your security details to
anyone else, you may give them to a TPP if it is necessary to do so.
5. We may refuse to allow a TPP to access your account if we are
concerned about unauthorised or fraudulent access by that TPP. If we
do this, we will tell you why (unless doing so would compromise our
reasonable security measures or otherwise be unlawful).
6. You must check the information provided to you by the TPP, to ensure
that they are authorised or permitted by law to provide payment
services to you. If we become aware that an unauthorised third party
is using your security details, we may block access to your account.
12. How long do we retain your personal data for?
1. We will only retain your personal data for as long as it is required in
relation to the purposes it was obtained for by us as detailed in this
notice. The periods for which we hold your personal data are set out
below:
1. When you have an account with us; we only keep details of your
personal information and details of your account for such period of
time as is necessary to permit us to comply with any legal or
statutory obligations after your account is closed and as may be
required to enable us to establish or defend any legal claims that
may arise in relation to your account.
2. When you apply for an account but are declined credit; we will keep
your personal data for statistical analysis, fraud prevention and
credit scoring purposes. If you have consented to receiving marketing
from us, in the event your application is declined, we will continue
to retain your personal data in order to send marketing to you.
Please note that you can withdraw your consent to receive marketing
from us at any time by contacting Customer Services, using the
unsubscribe link in any email we send you or on your online account
management page. Please see Section 17 for more information about how
we use your personal data for profiling, Section 19 about the right
to object to the processing of your personal data and Section 20
about where we rely on your consent to process your personal data;
3. FPAs 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 by them. For more details about
how long FPAs hold your personal data please contact us by calling
our Compliance Team on 0371 522 5146.
13. What measures do we have in place to safeguard your personal data?
1. We know how important it is to keep your personal data secure. We
protect your personal data when being transferred and when stored in IT
systems.
2. A variety of technologies are employed to protect the systems that are
used to store and manage personal data. To protect our systems and
networks from attack we use firewalls, encrypted hard drives, antivirus
software, host based intruder detection software and authenticated
access protection solutions. Our security solutions are designed in line
with industry standards to protect the personal data we store or
transmit.
3. Access to personal information is strictly controlled. We ensure access
to personal data is restricted to individuals on a need to know basis.
Training is provided to individuals working within the group who need to
access personal data to ensure that personal data is managed securely.
4. When we share your personal data with third parties and organisations as
set out in Section 6 we undertake appropriate due diligence with them to
ensure they are complying with the terms of their contract.
14. When do we transfer your personal data overseas?
1. We and third parties with whom we share personal data with may transfer
your personal data overseas so that we can manage your account and
provide other services from countries within the European Economic Area
(EEA) (where similar data protection standards apply as in the UK) and
countries outside the EEA. When personal data is transferred to
countries outside of the UK and the EEA those countries may not offer an
equivalent level of protection for personal information to the laws in
the UK. Where this is the case we and those third parties will ensure
that appropriate safeguards are put in place to protect your personal
information. For example, whenever FPAs transfer your personal data
outside of the UK and the EEA, they impose contractual obligations on
the recipients of that personal data to protect your personal data to
the standard required in the UK. They may also require the recipient to
subscribe to 'international frameworks' intended to enable secure data
sharing.
2. When we transfer personal data to Mastercard, Mastercard have binding
corporate rules in place to safeguard your personal data. A link to the
Mastercard binding corporate rules is found here.
3. We may process payments through other financial institutions such as
banks and the worldwide payments system operated by the SWIFT
organisation. These external organisations may process and store your
personal data abroad in order to fulfil any payment instructions for
example when you use your card and/or product. Additionally, the SWIFT
organisation has to disclose your personal data to overseas authorities
to help them to prevent and detect crime and terrorism. If these
authorities are outside the UK and the EEA, your personal information
may not be protected to the same standards as in the UK.
4. The countries to which your personal data is transferred and the
safeguards in place where personal data are transferred outside the UK
and the EEA are set out below:
1. United Kingdom
2. Germany (EEA)
3. Ireland (EEA)
4. Netherlands (EEA)
5. Poland (EEA)
6. USA
7. India
8. Canada
9. Australia
10. France (EEA)
11. Spain (EEA)
12. Iceland (EEA)
13. The safeguards that we rely on to protect personal data that is
transferred outside of the UK and the EEA include:
14. European Commission approved model contract clauses. Further details
about the model contract clauses is available here.
15. How do I find out about cookies?
1. We are committed to protecting your personal data (anonymous or
otherwise) that we collect about you online. Our Cookies Notice explains
how we use cookies, why, and how this allows us to improve our service.
It also tells you how you can manage what cookies are stored on your
device. Please read the Cookies Notice to find out more.
16. Why do we use credit scoring and automated decision making as part of your
application?
1. When you check your eligibility with us or apply to us for credit we may
use an automated system known as credit scoring to help us decide
whether to lend to you. It is a way of assessing how much you are able
to afford to borrow and how you are likely to manage your account. Most
lenders use credit scoring to help make fair and informed decisions
about lending.
2. Credit scoring takes account of information from three sources:
1. The information you give us on your application;
2. Information provided by CRAs and FPAs, including information about
how you manage similar accounts; and
3. Information that may already be held about you by us.
3. We may contact you to offer you the opportunity to have a credit limit
increase eligibility check based, in part, on open banking data. We will
assess how much you are able to borrow before deciding whether to
increase your credit limit. In this situation the credit scoring will
take account of information from four sources:
1. The information you give us on your application;
2. Information provided by CRAs and FPAs, including information about
how you manage similar accounts;
3. Information that may already be held about you by us; and
4. Open banking data held by other financial institutions.
4. Following a credit limit increase eligibility check under section 16.3,
the open banking data referenced at 16.3.4 will be used as part of any
further eligibility checks for a reasonable period of time.
5. Credit scoring methods are regularly reviewed to ensure they remain
fair, effective and unbiased. Using credit scoring helps us to lend
responsibly.
6. You have rights in relation to automated decision making. Please see
Section 19 for more details of these rights.
17. How do we use your personal data for profiling?
1. We use various profiling techniques to assist us with running our
business. By “profiling” we mean the automated analysis of personal data
about an individual to evaluate certain things about that individual -
basically drawing conclusions about an individual based on a statistical
model.
2. We use these techniques for instance in the course of evaluating
applications for cards and/or products, undertaking credit limit
increase eligibility checks, to manage your account, to guard against
fraud and for marketing and targeted advertising purposes.
3. You have a right to object in relation to profiling. Please see Section
19.1.7 for more details of this right.
18. How do we use your personal data if you are an additional cardholder?
1. If you are an additional cardholder, we will ask the primary cardholder
to provide us with your name, date of birth, email address, phone number
and confirmation that you are 18 or over and live at the same address as
the primary cardholder. We use this information to issue and send out
your card and PIN and to verify your online transactions. The legal
basis that we rely on to process your personal data is because it is in
our legitimate interests to obtain your information to enable us to
issue a card to you.
2. We will keep your personal data confidential and only share it with
other third parties and organisations for the purposes explained below:
1. With any third parties who carry out services on our behalf to help
us operate our business and to provide services. All these third
parties have a contract with us and have agreed to keep your personal
data confidential and secure and only to use it for the purposes that
we allow.
2. With any person working within the NewDay Group or the retailer group
to enable us to perform our obligations in relation to the provision
of the services or products to you;
3. With any firm, organisation or person together with whom we provide
products and services for example where we are providing a card
and/or product to you on behalf of a retailer. When we share your
personal data with such parties they may also be a controller for the
personal data they process. You should therefore read their privacy
notices very carefully to understand how they process your
information;
4. With any firm that provides analytical, market research or similar
services to us;
5. With any regulators, including the Financial Conduct Authority
(referred to throughout this notice as FCA), the ICO, the Financial
Ombudsman Service and other authorities including law enforcement
agencies and tax authorities, (including those overseas), where we
are required to disclose any personal data in order to comply with
our legal or regulatory obligations;
6. With any potential buyer, transferee, or merger partner and their
advisers in relation to any business transfer or re-organisation if
we decide to sell, transfer or merge part or all of our business or
assets, or any associated rights or interests or to acquire another
business. If we disclose your personal data for this purpose, we will
ensure that your personal data is kept confidential and only used it
in relation to the possible transaction(s). If the transaction(s) go
ahead, the purchaser, transferee or merger partner may use your
personal data in the same way as set out in this notice or provide
you with a new privacy notice explaining how your personal data will
be used by them; and
7. Where we have acquired your account from another creditor, with the
previous creditor for administrative, regulatory and legal purposes
and to help us deal with any complaints or other issues relating to
your account.
3. Please also see the following sections of this notice that are
applicable to additional cardholders:
2. Whom should I contact if I have questions about this notice?
3. What are personal data and special categories of personal data?
12. How long do we retain your personal data for?
13. What measures do we have in place to safeguard your personal data?
14. When do we transfer your personal data overseas?
15. How do I find out about cookies?
19. What rights do you have in relation to your personal data?
21. Why do we need to record phone calls with you?
19. What rights do you have in relation to your personal data?
1. You have a number of rights in relation to your personal data, these
include the right to:
1. Information - Be informed about how we use your personal data;
2. Access - Obtain access to your personal data that we hold;
3. Rectification - Request that your personal data is corrected if you
believe it is incorrect or incomplete;
4. Erasure - You do not have a blanket right to ask for deletion of your
data. A request that we erase your personal data is only valid in the
following circumstances:
1. If we are continuing to process personal data beyond the period
when it is necessary to do so for the purpose for which it was
originally collected;
2. If we are relying on consent as the legal basis for processing and
you withdraw consent;
3. If we are relying on legitimate interest as the legal basis for
processing and you object to this processing and there is no
overriding compelling ground which enables us to continue with the
processing;
4. If the personal data has been processed unlawfully (i.e. in breach
of the requirements of the data protection legislation); or
5. If it is necessary to delete the personal data to comply with a
legal obligation
5. Restriction - Ask us to restrict our data processing activities where
you consider that:
1. Personal data is inaccurate;
2. Our processing of your personal data is unlawful;
3. Where we no longer need the personal data but you require us to
keep it to enable you to establish, exercise or defend a legal
claim; or
4. Where you have raised an objection to our use of your personal
data.
6. Portability - Request a copy of certain personal data that you have
provided to us in a commonly used electronic format. This right
relates to personal data that you have provided to us that we need in
order to perform our agreement with you and personal data where we
are relying on consent to process your personal data.
7. Objection - Object to our processing of your personal data where we
are relying on legitimate interests or exercise of a public interest
task to make the processing lawful. If you raise an objection, we
will carry out an assessment to determine whether we have an
overriding legitimate ground which entitles us to continue to process
your personal data. If you object to us using your personal data for
marketing purposes, we will always stop such use of your data.
8. Automated decisions - Not be subject to automated decisions which
produce legal effects or which could have a similarly significant
effect on you.
1. As part of the processing of your personal data, decisions may be
made by automated processes. This means we may automatically
decide that you pose a fraud or money laundering risk if:
1. our processing reveals your behaviour to be consistent with
money laundering or known fraudulent conduct; or is
inconsistent with your previous submissions; or
2. you appear to have deliberately hidden your true identity.
2. If you apply to us for credit but we are unable to offer you
credit, you can contact us within 21 days of the date of your
application to ask to have the decision reconsidered.
2. We will always tell you about the outcome of a request you have made in
relation to the rights discussed above (except in relation to changes in
marketing preferences, which are mostly automated).
3. If you would like to exercise any of your rights or find out more,
please contact our data protection team at dpofficer@newday.co.uk or
customer services team on 0333 220 2520*. The table at the end of this
notice provides more details about the personal data that we use, the
legal basis that we rely on in each case and your rights.
4. In addition to the rights above, you also have a right under the
Consumer Credit Act 1974 to request a CRA to provide you with
information they hold about you. A fee is payable. For more information
about the fees charged please read the Credit Reference Agency
Information Notice.
20. Your marketing preferences
1. As part of the application process for a card and/or product or to check
your eligibility for one of our cards and/or products, we will ask you
if you wish to receive marketing from us. We will not send marketing to
you if you ask us not to. We conduct marketing via direct mail, phone,
email, SMS and online, including via social media and other digital
advertising channels (for example Google), broadcast channels (for
example TV) and our mobile apps.
2. If you agreed to receiving marketing from us, but no longer wish to
receive marketing from us you can opt-out in a number of ways as
follows:
1. Writing to Customer Services Team, NewDay Ltd, PO Box 700, Leeds,
LS99 2BD; or
2. Phoning us on 0333 220 2520*; or
3. Clicking on any unsubscribe link which will be provided on all
marketing emails or using any unsubscribe functionality in any text
messages from us; or
4. Following the instructions in any other form of marketing you have
received from us; or
5. Changing your marketing preferences on your online account management
page.
3. When you provide your consent to receive marketing from us and the
retailer we will pass details of your marketing preferences to the
retailer.
21. Why do we need to record phone calls with you?
1. We may monitor or record phone calls with you in case we need to check
that we have carried out your instructions correctly, to resolve queries
or issues, for regulatory purposes, to help improve the quality of our
service, to manage your account and to help detect or prevent fraud or
other crimes. Conversations may also be monitored for staff training
purposes.
*Calls are charged at a standard national rate. Call costs from mobiles and
other operators may vary so please check before calling. Calls may be recorded
and monitored for training and security purposes and to help us manage your
account.
PART 1 - QUICK CHECK OF NEWDAY'S USE OF YOUR PERSONAL DATA (INCLUDING PROCESSING
UNDERTAKEN WHERE NEWDAY RELIES ON LEGITIMATE INTERESTS)
Purpose Type of personal data used Legal basis for processing Which rights
apply?^ Assessing credit risk for credit applications to ensure that NewDay meet
its regulatory obligations to lend responsibly and to enter into a contract with
you Application data including bank account details full name, date of birth,
current and past addresses, phone number and e-mail address, employment
information including salary, residential type, marital status and details of
financial associates Contractual Performance and Legal Obligation The generally
applicable rights plus the right to data portability Assessing credit risk for
credit limit increases with the use of open banking data
Bank account details full name, date of birth, current and past addresses, phone
number and e-mail address, employment information including salary, residential
type, marital status and details of financial associates and open banking data
Please note that you can withdraw your consent to this processing at any time by
contacting Customer Services, or on your online account management page.
ConsentThe generally applicable rights plus the right to object Account
management to enable NewDay to operate and manage your account including sending
service messages via post, SMS, email, WhatsApp, push notifications and via your
online Account Manager Transaction data, loyalty points data, customer
communications, customer service records, complaint records and associated
documentation, current addresses, phone number and e-mail address Contractual
Performance The generally applicable rights plus the right to data portability
in relation to transaction data Supporting debtor tracing and debt collections
to enable NewDay to recover any unpaid monies from you Contact details,
including full name, date of birth, current and past addresses, phone number and
e-mail address and account data (including details of financial associates) and
transaction data Legitimate Interest The generally applicable rights plus the
right to object To sell or transfer your debt to another third party Application
data including previous application details, account data, device data and
transaction data Legitimate Interests The generally applicable rights plus the
right to object Promoting responsible lending and helping to prevent
over-indebtedness Application data including previous application details and
account data and details of financial associates and transaction data and open
banking data Legal Obligation The generally applicable rights plus the right to
object Helping prevent and detect crime and anti-money laundering services and
verify identity including compliance with Politically Exposed Persons (PEPS) and
Sanctions Regulations Application data including previous application details,
account data, transaction data Legal Obligation The generally applicable rights
Helping prevent fraud in order to protect us and you against any fraudulent
activity on your account Application data including previous application
details, behavioural biometric data, account data, device data and transaction
data Legitimate Interest The generally applicable rights plus the right to
object Complying with and supporting compliance with legal and regulatory
requirements to which NewDay is subject Application data including previous
application details, transaction data, loyalty points data, customer
communications, customer service records, complaint records and associated
documentation Legal Obligation The generally applicable rights Business
analytics including system testing Application data, contract details including
previous application details, information from business partners e.g. Experian,
information from marketing information providers, transaction data, loyalty
points data, customer communications, customer service records, complaint
records and associated documentation
Open banking data. Please note that you can withdraw your consent to this
processing at any time by contacting Customer Services, or on your online
account management page
Legitimate Interest
Consent The generally applicable rights plus the right to object Marketing
purposes including direct mail and targeted digital marketing to send you offers
about our goods and services and those of the retailer Previous application
details, information from business partners e.g. Experian, information from
marketing information providers, names, addresses, account data Legitimate
Interest The generally applicable rights plus the right to object Electronic
marketing purposes including, SMS and email, targeted marketing to send you
offers about our goods and services and those of the retailer Previous
application details, information from business partners e.g. Experian,
information from marketing information providers, names, addresses, email
address, phone number and account data Consent or legitimate interests depending
on the sign up journey that you followed when applying for your card The
generally applicable rights plus the right to object Information generated by
Cookies Browser data Consent The generally applicable rights plus the right to
object Assessing your ability to repay any credit owed to us Sensitive
categories of personal data including details relating to your health, criminal
convictions or alleged offences. Information from business partners e.g.
Experian. Legal Obligation The generally applicable rights To add additional
cardholders and enable processing of transactions by additional cardholders
Name, date of birth, email address, phone number, address and confirmation that
the additional cardholder is 18 or over. Legitimate interests The generally
applicable rights plus the right to object
^The following generally applicable rights always apply: right to be informed,
right of access, right to rectification, right to erasure, right to restriction
and rights in relation to automated decision making. Please see the “What rights
do you have in relation to your personal data?” Section 19 above for more
details of your rights and how to exercise them or go the Information
Commissioner's website at www.ico.org.uk.
Credit is provided by NewDay Ltd, a company registered in England and Wales with
registered number 7297722, registered office: 7 Handyside Street, London, N1C
4DA. NewDay Ltd is authorised and regulated by the Financial Conduct Authority
with number 690292 and is also authorised by the Financial Conduct Authority
under the Payment Services Regulations 2017 (Ref no: 555318) for the provision
of payment services.
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