Credit privacy policy
Art Money Pty Ltd
ABN 65 168 905 388
Australian Credit License 470221
20 Meagher Street
Chippendale, NSW 2008
Tel 1300 31 66 11
Privacy Policy and Collection Notice
Please read this privacy policy and collection notice carefully as we cannot process your loan application (to purchase art work from a participating gallery) if you do not acknowledge and agree to these terms:
You acknowledge that you have made a loan application from Art Money via its website. The loan application is for consumer credit related to the purchase of art work from a participating art gallery.
The Privacy Act 1988 (Cth)(the Act) allows for personal information, including ‘sensitive information’, ‘credit information’ and ‘credit eligibility information’ (which are defined in the Act) about you (as a loan applicant) to be collected and disclosed provided we have obtained your consent. In this document, and where appropriate a reference to personal information includes ‘sensitive information’, ‘credit information’ and ‘credit eligibility information’.
This privacy notice tells you how certain organisations collect personal information about you, what they use the personal information for and who they share the personal information with. If any of those organisations collect personal information that can be used to identify you, it will take reasonable steps to notify you of that collection.
We may (from time to time) update, vary, amend or replace this privacy notice by giving you notice about the changes either on our website or by notification to you.
In this notice, a reference to “we”, “us” or “our” (including any similar expression) is a reference to Art Money Pty Ltd (ABN 65 168 905 388) being the credit provider for the loan and having the contact details specified in the Schedule
Organisations that collect personal information about you
We will collect personal information about you relating to your loan application.
How we collect personal information from you
We will in relation to your loan application, collect personal information about you from you. Most personal information that we can collect is collected from the loan application and any supporting documentation supplied in connection with your loan application. If your loan application is approved, then we can also collect personal information about you from the records we maintain about the products and services you receive from us. We can check and verify that personal information from sources referred to in the loan application and/or in this privacy notice and consent.
How we collect personal information from other sources
We can collect personal information about you from other sources in any manner permitted by the Act. We will only collect personal information from other sources where it is reasonably necessary for us to do so in relation to or in connection with your loan application and your loan (if your loan application is approved and we lend you the money to make the purchase of art from a participating art gallery). Examples of such sources of personal information include:
- we obtain personal information (including credit information concerning your credit worthiness or history, consumer information and collection of overdue payments information either within or outside of Australia) from a Credit Reporting Body for any purpose described below;
- we obtain personal information about your credit application or loan from any organisation described or referred to in the section titled “Organisations that collect personal information about you”;
- if we are unable to contact you and we obtain publicly available personal information about you in order to update our records and your contact details;
- we check security details (in relation to the art work that we propose to secure by registering a security on the Personal Property Securities Register) from the relevant art gallery from where you intend to make your art work purchase, through public registers or our service providers including a Credit Reporting Body; or
- if there is a need to, we may potentially also exchange information with your legal, financial advisers or other representatives and advisors in relation to or in connection with your credit application or loan.
When the law authorises or requires collection of personal information
There are laws that affect organisations that require us to collect and disclose your personal information. For example, we are required to collect and disclose your personal information for assessment and verification under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth) and any rules, regulations or guidance notes made under or in connection with that Act (“AML/CTF Act”). We are entitled to request personal information from you in regards to compliance with the AML/CTF Act from you even if such information was previously sought and provided. You must comply with any request we make in this regard and if you do not provide the requested information we may be required to take action, including delaying or refusing the processing of any loan application, making funds available to you to purchase art from a participating gallery or disclosing information that we hold about you to our related bodies corporate, service providers or relevant government bodies and regulators including AUSTRAC (which is the body responsible for anti-money laundering and counter-terrorism compliance in Australia). In connection with these compliance matters, we have appointed participating art galleries as limited agents for the purposes of collecting your eligible photo identification for identification and verification purposes in relation to your loan / loan application.
How your personal information may be used
We may collect and disclose your personal information for purposes including:
- supplying (including procuring the supply to) you with information about loan products or related services;
- considering whether you are eligible for a loan or any related service you requested in your application;
- processing the loan application and providing you with a loan or related service (if we approve your loan application);
- administering your loan or any related service, for example, to answer requests or deal with complaints;
- identifying and verifying your identify (including at the point of sale but also subsequently, if we need to);
- telling you about other products or services we or our related companies make available and that may be of interest to you, unless you tell us not to (this relates to direct marketing);
- allowing us to run our business efficiently and to perform administrative and operational tasks;
- preventing or investigating any fraud or crime or any suspected fraud or crime;
- as required by any law, regulation or code binding on us; and
- any purpose to which you have consented.
You can tell us at any time if you no longer wish to receive direct marketing information or offers from us. We will process your request as soon as reasonably practicable after receipt of your request.
Also we may use personal information about you to:
- enable an insurer to assess the risk of providing insurance to the us or to address our arrangements with an insurer;
- consider hardship requests; and
- assess whether to securitise loans and to arrange securitising loans we make.
How we share your personal information
Sharing information with credit providers
We can seek from and use or give to another credit provider any information including relating to your credit worthiness, credit standing, credit history or credit capacity. In particular, we or any insurer we use may seek an opinion from a credit provider or a Credit Reporting Body and such person is authorised to provide an opinion on you.
Sharing information with third parties
We may seek from and use or disclose information about you to third parties in relation to: considering your application for credit; administering your loan; exercising rights under your credit contract; or, any insurance policy an insurer issues to us relating to your loan. These third parties may include:
- your representatives, attorneys, lawyers, accountants and agents that act on your behalf;
- your referees, including your employer or other individuals to confirm your identify and/or other details about you (if and when we need to check these matters);
- other insurers, re-insurers, claim assessors and investigators;
- other financial institutions including deposit taking institutions;
- organisations in debt collecting, purchasing or factoring debts;
- law enforcement agencies;
- our lawyers, agents, consultants, financial advisers and any other party involved with your loan;
- government and/or regulatory bodies including the Australian Taxation Office, the Australian Securities & Investments Commission, the Reserve Bank of Australia, the Australian Prudential Regulatory Authority and the Australian Financial Security Authority as required or authorised by any law. In many cases these organisations may share information with foreign authorities;
- Rating agencies, to the extent necessary to allow these agencies to rate particular structured / investment products that we may develop in connection with your loan;
- any organisation involved or connected with the securitisation of your loan, including loan servicers, trust managers, trustees and security trustees, insurers and re-insurers;
- organisations that provide us, with the infrastructure in order to provide the credit services to you, which includes 10Group (a related entity) which seconds certain individuals to us in order to supply services to you;
- organisations that provide us with product advice, planning, research and development;
- Mailing houses and tele-marketing agencies that assist us to communicate with you; and
- service providers including IT and data consultants, agents, contractors and advisers that assist us to conduct our business.
Sharing information with Credit Reporting Bodies
We can give to a Credit Reporting Body personal information (including overdue payments) about you including to allow a Credit Reporting Body to create or maintain a credit information file about you. A Credit Reporting Body may include information about you in reports that it gives other organisations (such as other credit providers) to help them assess your credit worthiness.
We will only share any credit information about you with a Credit Reporting Body if that body has a business operation in Australia and is unlikely to share credit eligibility information with organisations that do not have business operations in Australia.
Some of the information held by a Credit Reporting Body may reflect adversely on your credit worthiness, for example, where you fail to make payments or if you commit a series credit infringement (like obtaining credit by deception / fraud). If information of this nature is held on your credit file then this will likely materially affect your ability to obtain credit from other credit providers in the future.
Currently we deal with the Credit Reporting Bodies disclosed in the Schedule. Each Credit Reporting Body also has a policy about how they handle information about you. You should be able to obtain a copy of their policy by contacting them directly.
If you believe that you have been or are likely to be a victim of fraud (including identity fraud) you can request a Credit Reporting Body not to use or disclose the information they hold about you for a prescribed period of time (currently 21 days).
Sharing information with related companies
We may share information about you with our related companies for the purposes described above.
Sharing information outside of Australia
We may store information about you in cloud or other types of networked or electronic storage. As electronic or networked storage can be accessed from various countries through an internet connection it is not always practical to know in which country information about you may be held.
We will take reasonable steps to ensure that any overseas organisation that receives your personal information will comply with the Act.
If you do not provide personal information
If you do not provide your personal information to us, it may not be possible:
- to provide you with the product or service you have applied for. For example, if personal information is not disclosed to us we will not be able to process your loan application. If personal information is not disclosed to an insurer (if we require insurance in relation to your loan), it may not be able to process our request for insurance. In that case, we will likely not be able to proceed with your loan application;
- to manage or administer the loan we make to you;
- to verify your identity or protect against fraud; or
- to let you know about other products or services that might be suitable for your financial needs (unless you opt out of this by telling us that you do not wish to receive such information).
Information about other people
If for any reason you give us personal information about any other person in relation to the loan application or the loan:
- we are entitled to assume that you have sought their consent to the disclosure of such personal information to us;
- we have collected their personal information to assess the loan application, to manage any loan you receive from us and for any other purpose set out in this document;
- we may exchange this personal information with other organisations set out in this document;
- we handle their personal information in the same way as set out in this document and they can:
- access or request a copy of this privacy notice; or
- access the information we hold about them, by using the contact details for us in the Schedule; and
- you may not be able to get credit from us or we may not accept your loan application unless we obtain their personal information.
Anonymity and pseudonymity
We are not able to deal with a loan application if you do not wish to identify yourself. However, where possible we will provide information of a general nature such as for example, in relation to the products and services we supply, to unidentified individuals via our website.
Information security
We take reasonable steps to protect all information which we hold (including any personal or sensitive information) from misuse, loss, unauthorised access, modification or disclosure.
Marketing and opt-out
We may also use the information including personal information provided by you for marketing and research purposes, to analyse and improve products and services and to inform you of products and services provided by us, our related entities or preferred suppliers which we consider may be of value or interest to you, unless you tell us (see marketing opt) or have previously told us not to.
Accessing your Personal Information
Unless we are entitled to withhold access to your personal information, you have the right to request access to any personal information held by us which relates to you. We may charge a reasonable fee where access to personal information is provided. Any requests for access to your personal information should be made in writing to the Privacy Officer (specified below). You also have the right to request the correction of any personal information which relates to you that is inaccurate, incomplete or out-of-date.
If you require any further information about our management of personal information or have any queries or complaints, you should contact the relevant Privacy Officer for the relevant Organisation (specified in the Schedule).
Consent and agreement
By proceeding with your loan application via our website and in particular, by checking the box that you have “read and understood our privacy policy and collection notice” you will be taken to have received notification of this privacy policy and collection notice and given your agreement to the matters set out in this document.
Also, by proceeding with your loan application via our website and in particular, by checking the box that you have “read and understood our privacy policy and collection notice” you also declare that you are over the age of 18 years and that the information contained in the loan application is true and correct in every respect and it is upon this basis that you make the loan application.
Schedule
In this notice and acknowledgement:
Credit Reporting Body means:
Equifax Australia Business Information Services and Solutions Pty Limited
Address: Equifax, PO Box 967, North Sydney NSW 2059
Telephone: 138332 (8:30am – 6:00pm Monday – Friday)
Website: www.equifax.com.au
Online: www.mycreditfile.com.au
Equifax Australia's credit reporting policy is set out at www.equifax.com.au/privacy
Including any other Credit Reporting Body that we notify to you in relation to your application for credit or guarantee or loan.
Art Money means:
Art Money Pty Ltd
ABN 65 168 905 388
Australian Credit License 470221
Address: 20 Meagher Street, CHIPPENDALE NSW 2008
Telephone: 1300 31 66 11
Email: privacy@artmoney.com.au
Art Money New Zealand Limited
NZBN 9429042003243
PO Box 106-634
Auckland City 1143
New Zealand
Tel 0800 004 682
Privacy Policy and Collection Notice
Please read this privacy policy and collection notice carefully as we cannot process your loan application (to purchase art work from a participating gallery) if you do not acknowledge and agree to these terms:
You acknowledge that you have made a loan application from Art Money via its website. The loan application is for consumer credit related to the purchase of art work from a participating art gallery.
The Privacy Act 1993 (the Act) allows for personal information about you (as a loan applicant) to be collected and disclosed provided we have obtained your consent.
This privacy notice tells you how certain organisations collect personal information about you, what they use the personal information for and who they share the personal information with. If any of those organisations collect personal information that can be used to identify you, it will take reasonable steps to notify you of that collection.
We may (from time to time) update, vary, amend or replace this privacy notice by giving you notice about the changes either on our website or by notification to you.
In this notice, a reference to “we”, “us” or “our” (including any similar expression) is a reference to Art Money New Zealand Limited NZBN 94290420032243 being the credit provider for the loan and having the contact details specified in the Schedule
Organisations that collect personal information about you
We will collect personal information about you relating to your loan application.
How we collect personal information from you
We will collect personal information in relation to your loan application directly from you where practicable. Most personal information that we collect is collected from the loan application and any supporting documentation supplied in connection with your loan application. If your loan application is approved, then we can also collect personal information about you from the records we maintain about the products and services you receive from us. We can check and verify that personal information from sources referred to in the loan application and/or in this privacy notice and consent.
How we collect personal information from other sources
We can collect personal information about you from other sources in any manner permitted by the Act. We will only collect personal information from other sources where it is reasonably necessary for us to do so in relation to or in connection with your loan application and your loan (if your loan application is approved and we lend you the money to make the purchase of art from a participating art gallery). Examples of such sources of personal information include:
- we obtain personal information (including credit information concerning your credit worthiness or history, consumer information and collection of overdue payments information either within or outside of New Zealand) from a Credit Reporting Body for any purpose described below;
- we may obtain personal information about your credit application or loan from our related bodies corporate such as 10Group, and other organisations that provide us with the infrastructure in order to provide the credit services to you;
- if we are unable to contact you and we obtain publicly available personal information about you in order to update our records and your contact details;
- we check security details (in relation to the art work that we propose to secure by registering a security on the Personal Property Securities Register) from the relevant art gallery from where you intend to make your art work purchase, through public registers or our service providers including a Credit Reporting Body; or
- if there is a need to, we may potentially also exchange information with your legal, financial advisers or other representatives and advisors in relation to or in connection with your credit application or loan.
When the law authorises or requires collection of personal information
There are laws that affect organisations that require us to collect and disclose your personal information. For example, we are required to collect and disclose your personal information for assessment and verification under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 and any rules, regulations or guidance notes made under or in connection with that Act (“AML/CFT Act”). We are entitled to request personal information from you in regards to compliance with the AML/CFT Act from you even if such information was previously sought and provided. You must comply with any request we make in this regard and if you do not provide the requested information we may be required to take action, including delaying or refusing the processing of any loan application, making funds available to you to purchase art from a participating gallery or disclosing information that we hold about you to our related bodies corporate, service providers or relevant government bodies and regulators. In connection with these compliance matters, we have appointed participating art galleries as limited agents for the purposes of collecting your eligible photo identification for identification and verification purposes in relation to your loan / loan application.
How your personal information may be used
We may collect and disclose your personal information for purposes including:
- supplying (including procuring the supply to) you with information about loan products or related services;
- considering whether you are eligible for a loan or any related service you requested in your application;
- processing the loan application and providing you with a loan or related service (if we approve your loan application);
- administering your loan or any related service, for example, to answer requests or deal with complaints;
- identifying and verifying your identify (including at the point of sale but also subsequently, if we need to);
- telling you about other products or services we or our related companies make available and that may be of interest to you, unless you tell us not to (this relates to direct marketing);
- allowing us to run our business efficiently and to perform administrative and operational tasks;
- preventing or investigating any fraud or crime or any suspected fraud or crime;
- as required by any law, regulation or code binding on us; and
- any purpose to which you have consented.
You can tell us at any time if you no longer wish to receive direct marketing information or offers from us. We will process your request as soon as reasonably practicable after receipt of your request.
Also we may use personal information about you to:
- enable an insurer to assess the risk of providing insurance to the us or to address our arrangements with an insurer;
- consider hardship requests; and
- assess whether to securitise loans and to arrange securitising loans we make.
How we share your personal information
Sharing information with credit providers
We can seek from and use or give to another credit provider any information including relating to your credit worthiness, credit standing, credit history or credit capacity. In particular, we or any insurer we use may seek an opinion from a credit provider or a Credit Reporting Body and such person is authorised to provide an opinion on you.
Sharing information with third parties
We may seek from and use or disclose information about you to third parties in relation to: considering your application for credit; administering your loan; exercising rights under your credit contract; or, any insurance policy an insurer issues to us relating to your loan. These third parties may include:
- your representatives, attorneys, lawyers, accountants and agents that act on your behalf;
- your referees, including your employer or other individuals to confirm your identify and/or other details about you (if and when we need to check these matters);
- other insurers, re-insurers, claim assessors and investigators;
- other financial institutions including deposit taking institutions;
- organisations in debt collecting, purchasing or factoring debts;
- law enforcement agencies;
- our lawyers, agents, consultants, financial advisers and any other party involved with your loan;
- government and/or regulatory bodies including the Inland Revenue Department, Department of Internal Affairs, and the Financial Markets Authority as required or authorised by any law. In many cases these organisations may share information with foreign authorities;
- Rating agencies, to the extent necessary to allow these agencies to rate particular structured / investment products that we may develop in connection with your loan;
- any organisation involved or connected with the securitisation of your loan, including loan servicers, trust managers, trustees and security trustees, insurers and re-insurers;
- organisations that provide us with the infrastructure in order to provide the credit services to you, which includes 10Group (a related entity) which seconds certain individuals to us in order to supply services to you;
- organisations that provide us with product advice, planning, research and development;
- Mailing houses and tele-marketing agencies that assist us to communicate with you; and
- service providers including IT and data consultants, agents, contractors and advisers that assist us to conduct our business.
Sharing information with Credit Reporting Bodies
We can give personal information about you (including details of overdue payments) to a Credit Reporting Body, which may use this information to create or maintain a credit information file about you. A Credit Reporting Body may include information about you in reports that it gives other organisations (such as other credit providers) to help them assess your credit worthiness.
Some of the information held by a Credit Reporting Body may reflect adversely on your credit worthiness, for example, where you fail to make payments or if you commit a series credit infringement (like obtaining credit by deception / fraud). If information of this nature is held on your credit file then this will likely materially affect your ability to obtain credit from other credit providers in the future.
Currently we deal with the Credit Reporting Bodies disclosed in the Schedule. Each Credit Reporting Body also has a policy about how they handle information about you. You should be able to obtain a copy of their policy by contacting them directly.
If you believe that you have been or are likely to be a victim of fraud (including identity fraud) you can request a Credit Reporting Body not to use or disclose the information they hold about you for a prescribed period of time (currently 10 working days).
Sharing information with related companies
We may share information about you with our related companies for the purposes described above.
Sharing information outside of New Zealand
We may store information about you in cloud or other types of networked or electronic storage. As electronic or networked storage can be accessed from various countries through an internet connection it is not always practical to know in which country information about you may be held.
We will take reasonable steps to ensure that any overseas organisation that receives your personal information will comply with the Act.
If you do not provide personal information
If you do not provide your personal information to us, it may not be possible:
- to provide you with the product or service you have applied for. For example, if personal information is not disclosed to us we will not be able to process your loan application. If personal information is not disclosed to an insurer (if we require insurance in relation to your loan), it may not be able to process our request for insurance. In that case, we will likely not be able to proceed with your loan application;
- to manage or administer the loan we make to you;
- to verify your identity or protect against fraud; or
- to let you know about other products or services that might be suitable for your financial needs (unless you opt out of this by telling us that you do not wish to receive such information).
Information about other people
If for any reason you give us personal information about any other person in relation to the loan application or the loan:
- we are entitled to assume that you have sought their consent to the disclosure of such personal information to us;
- we have collected their personal information to assess the loan application, to manage any loan you receive from us and for any other purpose set out in this document;
- we may exchange this personal information with other organisations set out in this document;
- we handle their personal information in the same way as set out in this document and they can:
- access or request a copy of this privacy notice; or
- access the information we hold about them,
- by using the contact details for us in the Schedule; and
- you may not be able to get credit from us or we may not accept your loan application unless we obtain their personal information.
Anonymity and pseudonymity
We are not able to deal with a loan application if you do not wish to identify yourself. However, where possible we will provide information of a general nature such as for example, in relation to the products and services we supply, to unidentified individuals via our website.
Information security
We take reasonable steps to protect all information which we hold from misuse, loss, unauthorised access, modification or disclosure.
Marketing and opt-out
We may also use the information including personal information provided by you for marketing and research purposes, to analyse and improve products and services and to inform you of products and services provided by us, our related entities or preferred suppliers which we consider may be of value or interest to you, unless you tell us (see marketing opt) or have previously told us not to. You agree that where we send you commercial electronic messages, we do not need to include information in each message about how to unsubscribe from our mailing list.
Accessing your Personal Information
You have the right to request access to any personal information held by us which relates to you. This information will be provided to you unless we are entitled to withhold it. We may charge a reasonable fee where access to personal information is provided. Any requests for access to your personal information should be made in writing to the Privacy Officer (specified below). You also have the right to request the correction of any personal information which relates to you that is inaccurate, incomplete or out-of-date.
If you require any further information about our management of personal information or have any queries or complaints, you should contact the relevant Privacy Officer for the relevant Organisation (specified in the Schedule).
Consent and agreement
By proceeding with your loan application via our website and in particular, by checking the box that you have “read and understood our privacy policy and collection notice” you will be taken to have received notification of this privacy policy and collection notice and given your agreement to the matters set out in this document.
Also, by proceeding with your loan application via our website and in particular, by checking the box that you have “read and understood our privacy policy and collection notice” you also declare that you are over the age of 18 years and that the information contained in the loan application is true and correct in every respect and it is upon this basis that you make the loan application.
Schedule
In this notice and acknowledgement:
Credit Reporting Body means:
Veda Advantage Business Information Services Ltd
Address: Private Bag 92156, Auckland Mail Centre, Auckland 1142
Telephone: 0800 698 332 (8:30am – 5:00pm Monday – Friday)
Website: www.veda.co.nz
Online: www.mycreditfile.co.nz
Veda Advantage’s credit reporting policy is set out at www.veda.com.au/privacy
Including any other Credit Reporting Body that we notify to you in relation to your application for credit or guarantee or loan.
Art Money means
Art Money New Zealand Limited
NZBN 94290420032243
Address: PO Box Auckland City 1143, New Zealand
Telephone: 0800 004 682
Email: privacy@artmoney.com.au
Version 1.1 July 2022
Art Money UK Ltd
66 Old Compton Street
London, W1D 4UH, UK
Please read this Policy carefully as it explains how we process your personal data in relation to your finance application (to purchase artwork from a partner, meaning an art seller) and your rights.
You acknowledge that you have made a finance application from Art Money via its website. The application is for consumer credit related to the purchase of artwork from a participating art seller.
In this notice, a reference to 'we', 'us', 'our' or 'Art Money' (including any similar expression) is a reference to Art Money UK Limited (Company number 13322986) ("Art Money" "we" or "us") being the credit provider for the finance and having the contact details specified in Schedule 1 to this Policy.
We are a "controller" for the purposes of the Data Protection Act 2018 and the EU General Data Protection Regulation 2016/679 as incorporated into UK law (Data Privacy Laws). This means that we are responsible for, and control the processing of, the personal data that we collect about you. We are registered with the Information Commissioner's Office, or ICO, under registration number ZB120499.
We may (from time to time) update, vary, amend or replace this Policy by giving you notice about the changes either on our website or by notification to you.
Organisations that collect personal data about you
We will collect personal data about you relating to your finance application.
How we collect personal data from you
We will, in relation to your finance application, collect personal data about you from you. Most personal data that we can collect is collected from the finance application and any supporting documentation supplied in connection with your application. If your application is approved, then we can also collect personal data about you from the records we maintain about the products and services you receive from us. We can check and verify that personal data from sources referred to in the application.
The personal data collected in the above manner may include:
- Personal information - including full name, age & gender;
- Contact details - including email, residential address and mobile number;
- Financial information - including information about the amount of finance requested and term, employment status, residential status, personal income and expenses, assets and liabilities, household composition and referees;
- Identity verification information - including a photo of you with your driving licence or passport.
We need this information to verify your identity, consider your application for credit and to enter into and fulfil the credit contract with you. Our lawful basis for processing this information is that we need it for the purposes of the contract and to meet our legal obligations (for example, to comply with anti-money laundering laws). Further information in relation to our lawful bases are set out in Schedule 2 to this Policy.
Special categories of personal data
Special protection is given to certain kinds of personal information that is particularly sensitive, for example information about your health status, racial or ethnic origin, political views, religious or similar beliefs, sex life or sexual orientation, genetic or biometric identifiers, trade union membership or criminal convictions or allegations.
We may ask you to provide special category personal data when applying for finance with Art Money. In particular, we ask for biometric data as part of our identity verification process to remotely and securely on-board clients and partners, or may provide a video call option to verify your identity.
Technology underlying this service is provided by a third party company for the purpose of assessing whether identification documentation is genuine compared against biometrics. We obtain your consent to use your information in this way. This identity verification information is required to remain compliant with UK anti-money laundering laws.
When we collect your personal data from other sources
We will only collect personal data from other sources where it is necessary for us to do so in relation to or in connection with your finance application, and where we provide finance, including:
- if we are unable to contact you, obtaining publicly available personal data with your contact details in order to update our records and your contact details; and
- if there is a need to, exchanging information with your legal, financial advisers or other representatives and advisors in relation to or in connection with your credit application or finance.
- obtaining personal data (including credit information concerning your credit worthiness or history, consumer information and collection of overdue payments information) from a Credit Reference Agency to verify your identity and credit worthiness;
When the law authorises or requires collection of your personal data
There are laws that affect organisations that require us to collect and disclose your personal data. For example, we are required to collect and disclose your personal data for assessment and verification under anti-money laundering laws. We are entitled to request personal data from you in regards to compliance with such laws from you even if such information was previously sought and provided.
How your personal data may be used
We may collect and disclose your personal data for purposes including:
- supplying (including procuring the supply to you) of information about finance or related services;
- considering whether you are eligible for finance or any related service you requested in your application;
- processing the credit application and providing you with finance or a related service;
- administering your finance or any related service, for example, to answer requests or deal with complaints;
- identifying and verifying your identity (including at the time of purchase but also subsequently, if we need to);
- telling you about other products or services we or our related companies make available and that may be of interest to you, unless you tell us not to – please see 'Marketing and opt-out' below for further information;
- allowing us to run our business efficiently and to perform administrative and operational tasks;
- preventing or investigating any fraud or crime or any suspected fraud or crime;
- as required by any law, regulation or code binding on us;
- enable an insurer to assess the risk of providing insurance to the us or to address our arrangements with an insurer;
- considering hardship requests;
- assessing whether to securitise and to arrange securitising;
- conducting research and statistical analysis about our products and services, to improve our product and services and for business analytics purposes;
- notifying you of any changes to our products and services that may affect you; and
- any purpose to which you have consented.
Further information in relation to our lawful bases are set out in Schedule 2 to this Policy.
How we share your personal data
Credit checks
We will verify your personal identity and source of wealth from information you provide with Credit Reference Agencies, fraud agencies and other sources for the purposes of complying with UK anti-money laundering (AML) legislation.
We also procure your credit score from Credit Reference Agencies for the purposes of complying with our responsible lending obligations, for making a decision on the amount of credit we extend to you, and to comply with relevant UK laws. Our lawful basis is that it is necessary to enter into the contract with you.
We may also report back your repayment history to Credit Reference Agencies (including overdue payments) about you, to allow a Credit Reference Agency to create or maintain a credit information file about you. A Credit Reference Agency may include information about you in reports that it gives other organisations (such as other credit providers) to help them assess your credit worthiness.
Some of the information held by a Credit Reference Agency may reflect adversely on your credit worthiness - for example, where you fail to make payments or if you commit a series credit infringement (like obtaining credit by deception / fraud). If information of this nature is held on your credit file then this will likely materially affect your ability to obtain credit from other credit providers in the future.
Currently we deal with the Credit Reference Agencies disclosed in Schedule 1. The privacy notice at https://www.experian.co.uk/legal/crain/ sets out how they use your personal data and your rights.
Sharing with other third parties
We may seek from and use or disclose information about you to third parties in relation to:
- considering your application for credit;
- administering your credit;
- exercising rights or enforcing your obligations under your credit contract (including for the purposes of debt recovery); and
- any insurance policy an insurer issues to us relating to your loan.
These third parties may include:
- your representatives, attorneys, lawyers, accountants and agents that act on your behalf;
- your referees, including your employer or other individuals to confirm your identify and/or other details about you (if and when we need to check these matters);
- other insurers, re-insurers, claim assessors and investigators;
- other financial institutions including deposit taking institutions;
- organisations in debt collecting, purchasing or factoring debts;
- law enforcement agencies;
- our lawyers, agents, consultants, financial advisers and any other party involved with your loan;
- government and/or regulatory bodies;
- rating agencies, to the extent necessary to allow these agencies to rate particular structured / investment products that we may develop in connection with your credit;
- any organisation involved or connected with the securitisation of your finance, including loan servicers, trust managers, trustees and security trustees, insurers and re-insurers;
- organisations that provide us with the infrastructure in order to provide the credit services to you;
- organisations which enable us to remotely and securely on-board clients and partners by assessing whether identification documentation is genuine;
- organisations that provide us with product advice, planning, research and development;
- service providers including IT and data consultants, agents, contractors and advisers that assist us to conduct our business;
Occasionally, we may need to disclose your personal data to third parties where necessary for the legitimate interests of business or in order to comply with legal obligations:
- if we are under a duty to disclose or need to share your personal data in order to comply with any legal obligation (including a court order) or at a regulator's request; and
- for the detection or prevention of crime; and
- in the event that we sell or buy any business or assets, in which case we may disclose your anonymised data or personal data to the prospective seller or buyer of such business or assets.
International transfers
Art Money is a global fin-tech and some processes, including review of personal data for KYC and AML compliance purposes, may be carried out by Art Money staff or contractors in countries outside the UK. Data accessed from outside the UK will be used only for the purposes described elsewhere in this Privacy Policy.
Art Money may also store information about you in cloud or other types of networked or electronic storage. As electronic or networked storage can be accessed from various countries through an internet connection. The providers of these services are located in the US, Australia and New Zealand.
We will take all steps reasonably necessary to ensure that your personal data is handled securely and in accordance with this Policy and Data Privacy Laws. These include ensuring, where the country does not provide an adequate level of protection, that we enter into standard contractual clauses where appropriate. For further information about the safeguards in place, please contact the Privacy Officer using the details below.
If you do not provide personal data
If you do not provide your personal data to us, it may not be possible:
- to provide you with the product or service you have applied for. For example, if personal data is not disclosed to us we will not be able to process your credit application. If personal data is not disclosed to an insurer (if we require insurance in relation to your finance), it may not be able to process our request for insurance. In that case, we will likely not be able to proceed with your credit application;
- to manage or administer the credit we make available to you;
- to verify your identity or protect against fraud; or
- to let you know about other products or services that might be suitable for your financial needs (unless you opt out of this by telling us that you do not wish to receive such information).
Information about other people
If for any reason you give us personal data about any other person in relation to the credit application or the financing:
- we are entitled to assume that you have sought their consent to the disclosure of such personal data to us;
- we have collected their personal data to assess the credit application, to manage any credit you receive from us and for any other purpose set out in this document;
- we may exchange this personal data with other organisations set out in this document;
- we handle their personal data in the same way as set out in this document and they have the rights in respect of their personal data as set out in this Policy; and
- you may not be able to get credit from us or we may not accept your credit application unless we obtain their personal data.
Anonymity and pseudonymity
We are not able to deal with a credit application if you do not wish to identify yourself.
Information security
Art Money takes reasonable steps to protect all information it holds (including personal data) from misuse, loss, and unauthorised access, modification or disclosure.
Where appropriate Art Money uses secure transmission facilities. However, no transmission of information over the internet can be guaranteed to be completely secure and we do not warrant the security of any information transmitted to us over the internet.
Marketing and opt-out
We may also use the information including personal data provided by you for marketing and research purposes, to analyse and improve products and services.
You have the right to opt out of receiving marketing at any time. If you do not wish to receive any information about such products and services, you can contact the Privacy Officer or follow the unsubscribe instructions in the relevant marketing communication.
How long we keep your personal data
We will not retain your personal data for any longer than is necessary for our purposes, including for the purposes of satisfying any legal, accounting or reporting requirements.
We have a legal obligation to retain your personal data for at least 7 years after you cease to be a customer and will generally hold your customer and due diligence information.
We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. If you would like further information about our retention periods, please contact our Privacy Officer using the details below.
Automated decision-making
You have the right not to be subject to automated decisions that will create legal effects or have a similar significant impact on you, unless you have given us your consent, it is necessary for a contract between you and us or is otherwise permitted by law.
Sometimes we use automated decision-making for credit approvals, using an algorithm. The factors taken into account depend on the amount of credit you have requested, but may include your credit score, net income, assets and dependents. We request your consent to use your personal data in this way. If it is determined that you do not meet the criteria for credit approval, then we will not be able to proceed with your credit application and will inform you of this.
You also have certain rights to challenge automated decisions made about you. You can request human intervention in our decision making process, express your point of view, obtain an explanation and contest the decision. To exercise these rights, please contact the Privacy Officer, Art Money UK at privacy@artmoney.co.uk
Your rights
In addition to the right to be informed of how we process your personal data (as set out in this Policy), you have the right to access, correct and, in some cases, delete, restrict and object to how we process your personal data (if we are using it for marketing or relying on the legitimate interest lawful basis to process it).
Where processing is based on consent, you have the right to withdraw your consent at any time.
You may also ask, in certain circumstances, for a portable form of your personal data. If you wish to exercise any of these rights, please contact the Privacy Officer, Art Money UK at: privacy@artmoney.co.uk
We may not be able to fulfil every request – for example, we will not be able to delete any information which we are required to keep by law.
If you have any concerns or wish to raise a complaint on how we have handled your personal data, you can contact the Privacy Officer, or the data protection supervisory authority – in the UK, this is the Information Commissioner's Office (ICO), at https://ico.org.uk/.
Acknowledgement
By checking the box that you have read our privacy policy and collection notice, you will be taken to have received notification of this Policy and been informed of the matters set out in it.
Also, by proceeding with your credit application via our website and in particular, by checking the box that you have "read our Credit Privacy policy” you also declare that you are over the age of 18 years and that the information contained in the credit application is true and correct in every respect and it is upon this basis that you make the application.
Schedule 1
In this Policy:
Credit Reference Agency means:
Experian Limited AND/OR Equifax Limited AND/OR TransUnion International UK Limited.
Including any other Credit Reference Agency that we notify to you in relation to your application for credit or guarantee or loan.
Art Money means:
Art Money UK Ltd Company number 13322986
66 Old Compton Street, London, W1D 4UH, UK
Telephone: +44 800 368 5468
Email: info@artmoney.co.uk
Schedule 2
Our purposes and lawful bases for processing personal data