Privacy Policy

This Privacy Policy explains how Avalon Financial Limited (company number 16865484) trading as A1 Loans (“A1 Loans”, “we”, “us”, “our”) collects, uses, shares and protects personal data when you use www.a1loans.co.uk (the “Website”), contact us, make an enquiry, submit an application, or use our online products and services.

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Background

We respect your privacy and are committed to protecting your personal data in accordance with the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018, and other applicable data protection laws (“Data Protection Laws”).

This Website is not intended for children and we do not knowingly collect data relating to children.

This Privacy Policy should be read alongside any additional privacy notices we provide at specific points (for example, during an application, identity verification, or where we obtain third-party reports). This Privacy Policy supplements those notices and does not override them.

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The Products And Services We Provide

This Privacy Policy applies to personal data collected or generated in connection with:

• your use of this Website (including enquiry forms, calculators, and application journeys);

• our communications with you (including email, telephone and online messaging where available);

• assessment and administration of lending products and related services; and

• compliance, fraud prevention, security and risk management activities connected to those products/services.

Where you interact with us in other ways (for example by phone, email, post, or via an intermediary), we may provide additional privacy information at the point we collect your data.

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Important Information And Who We Are

Controller and group structure

Avalon Financial Limited (trading as A1 Loans) is the controller responsible for your personal data, unless we tell you otherwise at the point we collect it.

References in this Privacy Policy to “A1 Loans”, “we”, “us” or “our” refer to Avalon Financial Limited trading as A1 Loans. Where appropriate, the term may also include any successor entity and/or affiliated entities acting as processors on our behalf.

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Contact details

If you have questions about this Privacy Policy or wish to exercise your legal rights, contact us at:

• Email: Info@a1loans.co.uk

• Company: Avalon Financial Limited (trading as A1 Loans)

• Company number: 16865484

You have the right to complain at any time to the Information Commissioner’s Office (ICO) (www.ico.org.uk). We would appreciate the opportunity to address your concerns first, so please contact us in the first instance.

 

Third-party links

Our Website may include links to third-party websites, plug-ins or applications. We do not control those third parties and are not responsible for their privacy policies. Please review their policies before providing personal data.

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Changes to this policy and accuracy

We may update this Privacy Policy from time to time. The latest version will always be posted on our Website. Please ensure the personal data we hold about you is accurate and current, and tell us if it changes.

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The Types Of Personal Data We Collect

“Personal data” means information relating to an identified or identifiable living individual. It does not include anonymous data.

We may collect, use, store and transfer the following categories of personal data:

• Identity Data - name, title, date of birth and other identifiers you provide

• Contact Data - postal address, email address, telephone numbers

• Financial Data - bank details and payment card details (where you make payments or provide them during an application)

• Transaction Data - payments to and from you and product/service details

• Technical Data - IP address, browser type/version, device identifiers, time zone setting, operating system and platform

• Usage Data - how you use our Website and services

• Profile Data - preferences, feedback, survey responses and information you provide in free-text fields

• Marketing and Communications Data - your preferences for receiving marketing and your communication preferences

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Aggregated data

We also use Aggregated Data (statistical or demographic data). Aggregated Data is not personal data unless it can identify you.

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Special category data and criminal offence data

We do not normally collect special category personal data (such as health, ethnicity, religion) unless it is necessary and lawful. We may process limited information connected to identity verification, fraud prevention, and financial crime compliance, which can include information relating to criminal convictions/offences where permitted by law and necessary for those purposes.

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How Personal Data Is Collected

We collect personal data through:

• Direct interactions - when you complete forms, make enquiries, apply, call, email or otherwise correspond with us

• Automated technologies - cookies, server logs and similar technologies collecting Technical and Usage Data

• Third parties and public sources (where lawful) - including:

  • credit reference agencies and fraud prevention agencies

  • identity verification and AML/KYC providers

  • introducers/intermediaries (where applicable)

  • publicly available sources (for example Companies House and the electoral register)

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If you fail to provide personal data

Where we need personal data by law or to perform a contract and you do not provide it, we may be unable to proceed with your enquiry, application, or product/service. We will tell you if this applies.

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How We Use Your Personal Data And Lawful Bases

We only use your personal data when the law allows. The lawful bases we rely on include:

• Performance of a contract - to take steps at your request, assess eligibility, and administer products/services

• Legal obligation - to comply with legal/regulatory requirements (including anti-money laundering and fraud prevention)

• Legitimate interests - to operate our business effectively, manage risk, prevent fraud, and keep our systems secure (balanced against your rights)

• Consent - mainly for certain marketing communications where required (you can withdraw at any time)

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Purposes for using your personal data

We may use personal data to:

• respond to enquiries and provide information about our products/services

• assess applications, eligibility, affordability, and risk

• verify identity and prevent/detect fraud and financial crime

• obtain and review creditworthiness and fraud risk information (where relevant)

• manage and administer products/services (including payments, fees, arrears and collections)

• manage customer relationships and communications, including complaints

• operate, maintain and improve our Website and internal systems

• protect our business, customers and systems (security monitoring, auditing, troubleshooting)

• comply with laws, regulations, internal policies and procedures

• create anonymised analytics to help develop and improve our services

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Change of purpose

We will only use your personal data for the purposes we collected it for, unless we reasonably consider the new purpose is compatible with the original purpose. Where required, we will notify you and explain the relevant lawful basis.

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Automated Decision-Making, Profiling And AI

In some instances we use automated systems and profiling to support our processes. Profiling means using software to process your personal data to evaluate or predict certain things about you, such as application eligibility, fraud indicators, affordability factors, or account risk.

We may use these technologies for:

• identity verification and fraud screening

• creditworthiness and affordability assessment support

• monitoring for account risk and potential breach of terms

• improving our Website and processes (including analysing Website activity to identify friction and technical issues)

• personalisation of communications (including marketing preferences, where permitted)

Where automated processing is used, we apply appropriate safeguards and oversight. You may request human review (where applicable), express your view, and provide additional information by contacting us at Info@a1loans.co.uk.

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Marketing

We aim to provide you with choice and control.

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Promotional offers from us

We may contact you with information about A1 Loans products and services where permitted by law (for example, where you have enquired and have not opted out, or where you have consented where required).

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Third-party marketing

We will obtain express opt-in consent before sharing your personal data with third parties for their marketing purposes.

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Opting out

You can opt out of marketing at any time by contacting Info@a1loans.co.uk or using opt-out links where provided. Opting out will not affect service messages relating to your enquiry, application, or account.

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Disclosure Of Your Information To Third Parties

We may share your personal data with:

• Service providers (processors) that provide IT, hosting, analytics, CRM, communications, document management and payment services

• Professional advisers such as solicitors, auditors and compliance advisers

• Valuers and due diligence providers where required for a lending decision

• Credit reference and fraud prevention agencies (see section 9.1)

• Identity verification / AML / KYC providers (see section 9.2)

• Regulators, law enforcement and authorities where legally required

• Buyers / successors if we sell, transfer, merge or restructure parts of our business

We require third parties to respect the security of your personal data, keep it confidential, and only process it for specified purposes and in line with our instructions.

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Credit checks and fraud prevention checks

If you apply for a product or service, we may search your records at organisations such as credit reference agencies and fraud prevention agencies. These checks help us to verify identity, assess eligibility and affordability, manage risk, prevent fraud and money laundering, and trace and recover debts.

Credit and fraud-related information may be obtained from, shared with, or verified using organisations including (but not limited to):

• Equifax, Experian, TransUnion

• CIFAS (fraud prevention)

• National Hunter (fraud prevention)
  or other similar agencies and databases.

These agencies may record details of our search and/or your application and this may form part of your credit file. Other lenders and organisations may also be able to see certain search footprints depending on the type of check performed.

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Identity verification and biometric checks

To comply with legal obligations and manage fraud risk, we may use electronic identity verification. This may include document checks and, where appropriate, biometric checks (for example facial images/liveness) conducted through specialist providers.

Identity verification and biometric processing may be carried out by providers including (but not limited to):

• Onfido (Entrust)

• Jumio

• IDnow

• Trulioo
  or other similar identity verification providers.

Where biometric data is processed, it is used for identity verification and fraud prevention, handled securely, and retained only for as long as necessary for those purposes and to meet applicable legal/regulatory requirements.

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International Transfers

Some of our suppliers may process personal data outside the UK. Where we transfer personal data internationally, we ensure an appropriate level of protection, for example by using:

• countries recognised as adequate by the UK Government;

• the UK International Data Transfer Agreement (IDTA) or relevant UK addendum; and/or

• other lawful transfer mechanisms permitted under UK GDPR.

You can request further details of safeguards by contacting Info@a1loans.co.uk.

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Data Security - How We Safeguard Your Information

We have technical and organisational measures to protect personal data against loss, misuse, unauthorised access, alteration or disclosure. Access is limited to authorised personnel and suppliers with a business need to know and subject to confidentiality obligations.

No internet transmission is completely secure. Where you transmit data to us via the Website, you do so at your own risk, but we apply strong protections once received.

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How Long We Keep Your Personal Data

We keep personal data for as long as necessary for the purpose collected and to meet legal, regulatory, tax, accounting or reporting requirements. We may retain data longer if there is a complaint, dispute, suspected fraud, or prospect of litigation.

As a general guide:

• core customer records are typically retained for at least 6 years after the relationship ends (subject to legal/regulatory requirements); and

• enquiry/application data that does not proceed is typically retained for up to 18 months, unless we must retain it longer for compliance or risk management.

Where possible, we will securely delete or anonymise personal data when it is no longer required.

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Your Rights

You have rights under Data Protection Laws, including:

• access to your personal data (data subject access request)

• correction of inaccurate/incomplete data

• erasure (where applicable)

• restriction of processing

• objection to processing (including direct marketing)

• data portability (in certain circumstances)

• withdrawal of consent (where processing is based on consent)

• rights relating to automated decision-making (where applicable)

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Fees and verification

You will not usually have to pay a fee. We may request information to verify your identity.

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Time limits

We aim to respond within one month. Complex or multiple requests may take longer, and we will keep you informed.

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Questions And Concerns

If you have questions about this Privacy Policy or how we handle personal data, contact:

• Info@a1loans.co.uk

If you are not satisfied with our response, you may complain to the Information Commissioner’s Office (ICO).

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Cookie Policy

What cookies are

Cookies are small text files placed on your device when you visit a website. We also use similar technologies such as pixels and tags.

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How we use cookies

We use cookies to:

• operate the Website securely and enable core functionality

• remember preferences

• measure and improve performance (analytics)

• support relevant advertising (marketing cookies, where consent is provided)

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Types of cookies

• Strictly Necessary Cookies - required for the Website to function and remain secure

• Performance/Analytics Cookies - help us understand how the Website is used and improve it

• Marketing Cookies - help deliver and measure advertising, where permitted

Third-party content (e.g. embedded video or social media widgets) may set third-party cookies that we do not control.

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Managing cookies

You can manage cookies through your browser settings. If you disable cookies, parts of the Website may not work correctly.

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Updates

We may update this Cookie Policy from time to time. The latest version will be posted on the Website.