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Legal — Document 01

Privacy Policy .

How Adlib Loans Limited collects, uses, shares, and protects your personal data — in plain English, with the legal specifics underneath.

Version
2.1
Effective
1 January 2025
Last reviewed
1 January 2025
Next review
1 January 2026
Controller
Adlib Loans Limited
Summary

The short version: We collect the information we need to assess your loan application and service the loan afterwards. We don't sell your data. We don't share it with anyone who isn't either performing a service for us or required by law. You have rights over your data, and we'll always act on them within the timescales the law requires.

  • We never sell your personal data to third parties.
  • Soft search only when you check your rate.
  • UK data centres — your data never leaves the UK.
  • You can ask us to delete your data at any time.
01

Who we are

Adlib Loans Limited ("Adlib", "we", "us", "our") is a company registered in England and Wales under company number [COMPANY_NUMBER], with its registered office at [REGISTERED_OFFICE_ADDRESS].

We are authorised and regulated by the Financial Conduct Authority (FRN [FCA_FRN]) and registered with the Information Commissioner's Office (registration [ICO_REG]).

For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, Adlib Loans Limited is the data controller in respect of the personal data described in this policy.

02

Data we collect

2.1 Information you give us

  • Identity data — name, date of birth, nationality, photo ID (passport or driving licence), signature.
  • Contact data — address history, email, phone numbers.
  • Financial data — income, employment status, existing debts, bank statements, tax returns (for business applicants).
  • Application data — loan amount, term, purpose, and any information you give us in correspondence.
  • Business data — for company applicants, registered name and number, trading address, directors' details.

2.2 Information we collect automatically

  • Technical data — IP address, browser type, device information, operating system.
  • Usage data — pages viewed, time on site, application progress.
  • Cookies — see section 10 below for details.

2.3 Information from third parties

  • Credit reference agencies — credit score, account history, electoral roll, insolvency records.
  • Fraud prevention agencies — identity verification and fraud databases.
  • Open banking providers — with your explicit consent, transaction data from your nominated bank account.
  • Public registers — Companies House, Insolvency Service, and similar.

2.4 Special category data

We do not routinely collect special category data (such as health, ethnicity, religion, or sexual orientation). Where it arises incidentally — for example, in a note about a medical emergency affecting repayment — we handle it under the substantial public interest condition (Article 9(2)(g) UK GDPR) solely to support a vulnerable customer.

03

How we use your data

We use your personal data for the following purposes:

  • Assessing your loan application, including running a soft credit search.
  • Verifying your identity and preventing fraud.
  • Making a lending decision and, if approved, issuing and administering your loan.
  • Servicing the loan, including collecting repayments and managing arrears.
  • Complying with our legal and regulatory obligations (FCA, HMRC, anti-money-laundering rules).
  • Communicating with you about your application or your loan.
  • Improving our products and services.
  • Where you've opted in, sending you marketing about our products.

We will not use your data for any purpose incompatible with those listed above without first informing you and, where required, obtaining your consent.

04

Lawful basis

Under UK GDPR, we must have a lawful basis for processing your data. We rely on the following:

Contract
Processing necessary to enter into or perform your loan agreement — including assessing your application, issuing funds, and collecting repayments.
Legal obligation
Compliance with FCA rules, anti-money-laundering regulations, tax reporting, and responding to lawful requests from authorities.
Legitimate interests
Fraud prevention, network and information security, improving our services, and exercising or defending legal claims. We balance these against your rights and freedoms.
Consent
For marketing emails and SMS, and for Open Banking access to your bank account. You can withdraw consent at any time.
05

Credit reference agencies

When you check your rate or apply for a loan, we share your information with credit reference agencies (CRAs). The three main CRAs in the UK are Experian, Equifax, and TransUnion.

Soft search: When you check your rate, we run a soft search. This is visible only to you. It does not affect your credit score, and other lenders cannot see it.

Hard search: If you accept a formal offer from us, we run a hard search. This is visible to other lenders and may affect your credit score for a short period.

The CRAs will record details of the search and any subsequent loan, and may share this information with other organisations for the purposes set out in their own privacy notices. We recommend reading the CRA privacy notices at:

06

Who we share data with

We do not sell your personal data. We share it only with organisations that help us deliver our service, or where the law requires it. This includes:

  • Credit reference agencies — as described in section 5.
  • Fraud prevention and identity verification providers — for anti-money-laundering and KYC checks.
  • Payment processors and banks — to issue funds and collect repayments.
  • Debt collection agencies — only if your loan falls into serious arrears and after we've contacted you.
  • Professional advisers — auditors, solicitors, insurers, and compliance consultants under confidentiality obligations.
  • Regulators and law enforcement — the FCA, ICO, HMRC, police, and courts, when legally compelled.
  • Our technology providers — cloud hosting, email delivery, and analytics, all under data processing agreements.

Where we use a processor, we require them by contract to protect your data to the same standard we do, and to use it only for the purposes we specify.

07

International transfers

Your data is stored on servers located in the United Kingdom. Where we use a processor that operates outside the UK (for example, an email service with servers in the EU or US), we ensure appropriate safeguards are in place:

  • An adequacy decision from the UK Government, or
  • The UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses.

You can request a copy of the safeguards we rely on by emailing privacy@adlibloans.com.

08

How long we keep it

We keep personal data only as long as necessary for the purposes we collected it for, and to meet legal obligations.

Declined applications 12 months from decision
Withdrawn applications 12 months from withdrawal
Live loans Duration of loan + 6 years
Complaints records 6 years from resolution
Marketing consent Until withdrawn + 2 years

When we no longer need your data, we securely delete or anonymise it in line with our data retention schedule.

09

Your rights

Under UK GDPR, you have the following rights in relation to your personal data:

Access

Request a copy of the data we hold about you.

Rectification

Ask us to correct inaccurate or incomplete data.

Erasure

Ask us to delete your data where we have no ongoing lawful basis to hold it.

Restriction

Ask us to pause processing while a dispute is resolved.

Portability

Receive your data in a machine-readable format or have it sent to another provider.

Object

Object to processing based on legitimate interests, including direct marketing.

Withdraw consent

Where processing relies on consent, withdraw it at any time. Withdrawal doesn't affect the lawfulness of processing before the withdrawal.

How to exercise your rights: Email privacy@adlibloans.com or write to the Data Protection Officer at our registered office. We'll respond within one calendar month. If your request is complex, we may extend this by a further two months and will tell you if so.

If you're unhappy with how we've handled your data, you can complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113. We'd appreciate the chance to put things right first — please contact us before escalating.

10

Cookies

We use cookies and similar technologies on our website. Cookies are small text files stored on your device. We use them for three purposes:

  • Strictly necessary — required for the site to function (e.g. security, session management). These cannot be disabled.
  • Analytics — help us understand how visitors use the site. Set only if you accept.
  • Marketing — used to show relevant ads and measure campaigns. Set only if you accept.

You can manage your cookie preferences at any time via the cookie banner or your browser settings. Note that disabling certain cookies may affect the functionality of the site.

11

Security

We take the security of your personal data seriously. Our safeguards include:

  • Encryption of data in transit (TLS 1.3) and at rest (AES-256).
  • Access controls with multi-factor authentication for all staff.
  • Role-based permissions — staff can only see the data they need for their role.
  • Regular penetration testing and security audits.
  • Staff training on data protection and information security at induction and annually.
  • Documented incident response procedures, including notifying the ICO within 72 hours of a reportable breach.

No system is perfectly secure. If you suspect your account has been compromised or you notice suspicious activity, contact us immediately at security@adlibloans.com.

12

Automated decisions

We use automated systems to help assess your application — for example, to run initial affordability calculations and to check your details against fraud and identity databases. However:

  • A human underwriter reviews every final decision before an offer is issued or a decline becomes final.
  • You have the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects.
  • You can request human intervention, express your point of view, and contest an automated decision.

To exercise these rights, contact privacy@adlibloans.com.

13

Children

Our products are only available to individuals aged 18 or over. We do not knowingly collect personal data from anyone under 18. If you believe a minor has provided us with their data, please contact us and we will delete it promptly.

14

Changes to this policy

We may update this policy from time to time to reflect changes in our practices, technology, or the law. The "last reviewed" date at the top of this page shows when the policy was most recently revised.

Where changes are material — for example, if we introduce a new use of your data — we will notify you by email before the change takes effect, and where required seek your consent.

15

How to contact us

For any question about this policy, or to exercise any of your data rights, contact us using the details below.

Data Protection Officer
Adlib Loans Limited, [REGISTERED_OFFICE_ADDRESS]
Phone
[PHONE_NUMBER]
Post
Data Protection Officer, Adlib Loans Limited, [REGISTERED_OFFICE_ADDRESS]
Supervisory authority
Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF · ico.org.uk
End of document · Privacy Policy v2.1
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