This Website (https://studentmoney.io) is operated by Future Finance, which is the trading name of Future Finance Loan Corporation Limited (we, us, Future Finance).
We are committed to protecting the privacy, confidentiality and security of the personal information that we hold and this Policy describes the privacy practices of Future Finance (including its subsidiaries and affiliated companies) with respect to information relating to you that you or third parties provide to Future Finance, including information collected or provided on this Website. In particular, this Policy explains what information we collect about you, what we use that information for, the lawful basis on which that information is used and who we give that information to. It also sets out your rights in relation to your information and who you can contact for more information or queries.
Future Finance is a data controller and is registered in the UK with the Information Commissioner’s Office (the ICO) under registration number ZA134468. Our lead supervisory authority in the EU is the Data Protection Commission in Ireland.
Personal information we may collect about you
Information you give us when you contact us (for example, through this Website or by telephone or e-mail): the personal information that you might give to us typically includes your name, email address, home address, date of birth, age, gender,[identification documents, country of residence, and other information such as financial and tax-related information, bank account details or demographic information when you complete forms and/or surveys. This information may be given on our Website or when you contact us directly, for example through our customer service department, either online or by telephone (our calls are recorded for training and monitoring purposes).
Information we collect about you and your device: in general, each time you visit the Website we automatically collect information about you from the way you interact with us or others, such as:
- details of your usage of the Website, including what pages of the Website you have visited and whether you have clicked on images or links on those pages (this may be user specific or aggregate); and
How we use your personal information
We use your information in various ways, such as:
- for administrative and IT purposes, for example to update/maintain our records, to carry out insurance, audit and similar administrative purposes and to manage our IT resources and infrastructure;
- to correspond and manage our relationship with you (including responding to any requests or queries you submit through our Website)
- to enhance your experience of our Website and of our services, for example by conducting statistical analysis or for editorial or feedback purposes for our advertiser affiliates;
- to provide you with marketing communications from us (subject to any consents that we are legally required to obtain from you to send such communications and which you can withdraw by opting out at any time) and such communications will from time to time include information on new content on this Website, as well as information on our products, services and initiatives (such as the Future Finance Scholarship Fund and other product development and marketing initiatives of Future Finance) and those of our selected partners. Such communications may also include invitations to events or networking opportunities that are connected to Future Finance;
- to satisfy applicable legal or regulatory requirements and respond to requests/communications from competent public or judicial authorities; and
- to protect our rights and those of our customers.
Disclosure of your information
While we do not generally request or seek special categories of personal data, in certain limited circumstances where you freely volunteer such information (including health or medical data) to us by phone or writing or on our Website, based on your explicit consent we may use this data for the purposes outlined in this Policy. Such consent can be withdrawn at any time by using the contact details in the contact section below.
We may share your information with selected third parties including:
- Service Providers: We contract with service providers to perform certain functions on our behalf. Examples include database providers, site analysis providers, IT support providers, consultants (including lawyers and accountants) and customer services platform providers (including Zendesk, Inc.). Their access is limited only to the personal data needed to perform the functions carried out on our behalf, and only for the purpose of performing those functions;
- Other disclosures: We may disclose your personal information to third parties for the following legitimate business purposes:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- If we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
- To our professional advisers where required to advise us from time to time and always subject to a duty of confidentiality (including lawyers, tax advisors and accountants);
- To other members of our group where required for management information and forecasting purposes;
- If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request, this includes exchanging information with other companies and organisations for the purposes of fraud prevention; and
- To competent authorities (including regulatory or enforcement bodies or courts) where necessary in connection with any regulatory interaction or legal proceedings.
Our legal basis for using your personal information as outlined above
We use your personal information for a variety of reasons, upon different legal bases including:
- For the performance of any agreement with you or to take steps at your request prior to entering into an agreement with you.
- Where necessary for our legitimate interests, for example in managing and monitoring our website operation, responding to any requests or queries that you submit to us, benefitting from cost effective services and exercising our rights under Articles 16 and 17 of the Charter of Fundamental Rights in the EU, including our freedom to conduct a business and right to property.
- Where necessary in order to comply with a legal obligation, for example making reports to our regulatory authority or to law enforcement agencies.
Where our use of your data is not necessary for one of the purposes outlined above we may seek your consent to use it in a particular way, for example if we ask you to complete a customer survey. Where we ask for your consent you are free to refuse our use of the data for those purposes and you may withdraw your consent at any time by contacting us using the details set out below.
When you submit information to us through the Website you may be asked whether we can contact you by telephone, SMS, email or by post to provide you with information about new content on this Website, as well as information on our products, services and initiatives (such as the Future Finance Scholarship Fund and other product development and marketing initiatives of Future Finance) and those of our selected partners. If you consent, we will give you the opportunity to change your consent preferences for receiving such marketing communications at any time afterwards in the following ways:
- Via email: Click the “Unsubscribe” link in any email communication and submit your email address on the next screen or email us at email@example.com;
- Via our Website: Update your contact preferences in the customer account section; or
- Via telephone: Call us on +44 (0)20 3743 8700.
If you withdraw your consent to our use of your information for direct marketing purposes, we will process your request as soon as possible. Please note that we reserve the right to take reasonable steps to authenticate your identity with respect to any such request.
Direct marketing communications about products, services and initiatives of our selected partners will be sent to you by us and only where we are legally permitted to send you such communications (because, for example, you have consented to receiving such communications). Like us, our selected partners operate in the student information and/or financial services industries. Any direct marketing communication you receive from us in relation to our selected partners will relate to products, services and initiatives offered by them that might be of interest to you. These products, services and initiatives will also be consistent with the types typically offered by suppliers in the student information and/or financial services industries. Our selected partners may include ClearScore; the Student Room; and the Tab.
How we keep your information secure
We have measures in place to protect the security and confidentiality of your information and we strive to keep it accurate. We only keep your information for as long as is necessary. We generally keep records of any transactions that you enter into for a minimum of six years.
Some of the security measures include:
- We work to protect the security of your personal data during transmission by using Secure Sockets Layer (SSL) software, which encrypts personal data you input.
- We store personal data in an encrypted database.
- We transmit personal data in an encrypted format.
- Our networks are secured with certified firewalls in a multi-layered fashion with redundancy.
We have offices located in the United States from which we perform data processing services. In order to properly protect information subject to transfers from the European Economic Area (EEA) to the United States, we have put adequate safeguards in place by entering into the European Commission’s model clauses. You can find out more about the model clauses at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en. You can also obtain more information on our safeguards by contacting us using the details in “Contact” below.
If we otherwise transfer your personal data to a country outside the EEA we will ensure that it is afforded the equivalent level of protection that it would receive in the EEA in one of the ways prescribed under the GDPR.
How long your personal information will be stored for
We only keep your personal information for as long as is necessary to fulfil the purposes for which we use it. This means that we may retain your personal data for up to 6 years after our relationship with you comes to an end. Alternatively, we may retain your personal data for a shorter period after the end of our relationship with you where such shorter retention period only is necessary to fulfil the purposes for which we use your personal data. We will delete all your personal data after the end of its retention period unless we are subject to a legal requirement to retain it for longer or in other exceptional circumstances (for example where we need to retain the data in connection with legal proceedings).
Your personal information is protected under data protection law and you have a number of rights (explained below) which you can seek to exercise. Please contact us using the details shown below if you wish to do so, or if you have any queries in relation to your rights. If you seek to exercise your rights, we will explain to you whether or not the right is available to you as these rights do not apply in all circumstances.
Right of access
Subject to certain exceptions, you have the right of access to information that we hold about you upon request. You can exercise this right by making a request in writing, by email or telephone using the contact details in the contact section below.
Right to rectify your personal information
If you discover that the information we hold about you is inaccurate or incomplete, you have the right to have this information rectified (i.e. corrected).
Right to be forgotten
You may ask us to delete information we hold about you in certain circumstances; this is often referred to as the ‘right to be forgotten’. This right is not absolute and only applies in particular circumstances. It may not therefore be possible for us to delete the information we hold about you, for example, if we have an ongoing contractual relationship or are required to retain information to comply with our legal obligations or to exercise or defend legal claims.
Right to restriction of processing
In some cases you may have the right to have the processing of your personal information restricted. For example, where you contest the accuracy of your personal information, its use may be restricted until the accuracy is verified. You have the right to ask us not to use your information for marketing purposes. We will ask for your consent to use your information for these purposes when we collect it and you can exercise your right to prevent such processing by checking certain boxes on our Website or other forms we use to collect your data. You can also exercise the right at any time by contacting us by post or email using the details in the contact section of this Policy (see below).
Right to object to processing
You may object to the processing of your personal information (including profiling) when it is based upon our legitimate interests. You may also object to the processing of your personal information for the purposes of direct marketing (including profiling to the extent it relates to direct marketing) and for the purposes of statistical analysis. We will assess each request on a case by case basis as required by data protection law.
Right to data portability
You have the right to receive, move, copy or transfer your personal information to a controller which is also known as ‘data portability’. You have the right to this when we are processing your personal information based on consent or on a contract and the processing is carried out by automated means. You should note that this right is different from the right of access (see above) and the types of information you can obtain under the two separate rights may be different.
If you have any questions about how we treat your personal data and protect your privacy or if you have any comments or wish to seek to exercise any of your rights as outlined above, please contact us:
By post to Future Finance Loan Corporation Limited, Third Floor, One Grand Parade, Dublin 6 Ireland D06 R9X8, by email to firstname.lastname@example.org or by telephoning us on +44 (0)20 3743 8700.
If you have a complaint, please contact us and we will investigate it and give reasonable redress if we consider it appropriate to do so.
You also have the right to complain to your local data protection supervisory authority. If you are in the UK, this is the Information Commissioner’s Office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, telephone 0303 123 1113. www.ico.org.uk If you are in Ireland or if your complaint relates to cross border processing issues, our lead supervisory authority is The Data Protection Commission, Canal House, Station Road, Portarlington R32 AP23 Co. Laois, telephone +353 57 8684800, email email@example.com.
Conditions of use and changes to this policy
If you choose to visit our Website, your visit and any dispute over privacy, is subject to this Policy. We may make changes to the policy from time to time to reflect changes to our operations or legal or regulatory requirements; if we do so we will put a the updated copy on our website and notify you of this.