Kuflink Group Plc & subsidiaries
Updated 09 June 2021
1.1 We are committed to protecting your privacy rights as a consumer of our services. Our policy is to respect and protect your rights to privacy.
1.2.Kuflink means Kuflink Group Plc and its subsidiaries.
1.3.All information you provide to us will be held by Kuflink on UK based servers. Unless otherwise specified in point 9. Kuflink will not hold, transfer or use your data outside the European Economic Area (EEA), nor will we share it with other, within or outside of the EEA (except when we believe in good faith that the law requires it).
1.4.We collect data on all our users in order to continually improve the services and products we offer. We also collect data to enter commercial arrangements which can include the sale of advertising space. Kuflink adheres to UK Data Protection Legislation which, from 25th May 2018, includes EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).
1.5.This privacy notice only relates to Kuflink’s website and platform and does not extend to your use of the internet outside of the Kuflink site.
2.1.Kuflink Group Plc is registered at 21 West Street Gravesend, Kent DA11 0BF under company number 09084634.
2.2.Kuflink Ltd is registered at 21 West Street Gravesend, Kent DA11 0BF under company number 08460508.
2.3.Kuflink Bridging Ltd is registered at 21 West Street, Gravesend, Kent DA110BF under company number 07889226.
2.4 Kuflink One Ltd is registered at 21 West Street, Gravesend, Kent, DA11 0BF under company number 12206864.
3.1.Before using our services and purchasing our products, we require that each user undertakes checks for the purposes of verifying your identity and preventing fraud and money laundering. These checks require Kuflink to collect and store personal data about you.
3.2.Details of personal data we may need to collect to process these checks include, but are not limited to: name, address, date of birth, contact details, bank account numbers, national insurance number and device identifiers including IP addresses.
3.3.Kuflink may need to enable law enforcement agencies access to your personal data to detect, investigate and/or prevent crime.
3.4.We process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and verifying identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested.
3.5.Fraud prevention agencies can hold your personal data for different time periods, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.
3.6.As part of the processing of your personal data, decisions may be made by automated means. This means we may automatically decide that you pose a fraud or money laundering risk if our processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct, or is inconsistent with your previous submissions, or you appear to have deliberately hidden your true identity. You have rights in relation to automated decision making: if you want to know more please read section 7.
3.7.If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services or financing you have requested or to employ you, or we may stop providing existing services to you.
3.8.A record of any fraud or money laundering risk will be retained by the fraud prevention agencies and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details below.
3.9.Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.
4.Data collected by Kuflink
types of personal data that we collect and process about you will depend on your interactions with Kuflink and what products, you use.
The data collected may fall into the below categories
4.2 We will collect the information below in
different ways depending on how you decide to make contact with us.
Direct - where you have come to Kuflink directly through our website.
1. Information provided when you apply for any of our products
2. Information provided when you use any of our online forms
3. Information provided or that we collect when using our
4. Information provided when communicating with us in writing, email, SMS or phone
5. Information we obtain when you engage with us across social media platforms
Third Party - where a
broker has introduced you to Kuflink or a third party is acting
on your behalf and we have authority for them to act:
1. Information that the third party provides as part of
the application process, or on any of our online forms
2. Information the third party provided when
communicating with us in writing, via email, SMS or by phone
3. Information provided to us on your behalf by your
representatives engaging with us for you
1. Information you have entered on the comparison site
as part of the application process
4.3 Special Category data
Data protection law requires us to treat special
category data carefully. Special category data includes biometric data whether that be physical, physiological or behavioural characteristics about you, health
data, criminal convictions, and any religious or political data.
We’ll only use special category data in the following scenarios:
-detecting and preventing financial crime,
-verifying your identity using biometric data; and
-making our services accessible to customers.
We will also only process special categories of
information where we’ve obtained your consent or where one of the
limited grounds on which we can process special category data applies.
do not monitor your use of the Internet, but we do use cookie technology to
monitor your use of Kuflink. This information is not stored alongside your
personal data and will only be used on an anonymous, aggregated basis. We may
process your personal data in conjunction with the documents and forms
downloaded in order to maintain and improve the facilities we offer and to send
you alerts about important updates to such content.
5. Information we collect from other sources
5.1. We may on occasion obtain information from other
sources, this helps us to offer you our products and services and to
operate our platform. This will, on occasion, include personal information and may be obtained from sources such as:
- Our group companies
- Companies that introduce you to us
- Credit Reference Agencies
- Comparison Websites
- Social Networks
- Fraud Prevention Agencies
- Public Information services such as Companies
- Land Registry
- Government Agencies
- Law Enforcement Agencies
we use your data
General Data Protection Regulation states that we can only use
personal information if we have a genuine reason to do. This includes providing it to third parties
outside of the Kuflink Group
will only use your personal information for one of the following reasons
· Fulfilling Contracts we have with you
· When we are legally obliged to
you have given consent to us
it is in our legitimate interest i.e. when we have a business or commercial reason to use the information.
is a list of all the ways in which we can use your personal information and the
reason we rely on to do so.
|What we use your personal information for||When we would use the information||Our legitimate interests|
| || || |
|To provide a decision in principle when applying for a loan||Our legitimate interest||Ensuring customers have a clear understanding of the product they may be accepted for without there being a detrimental affect on their credit rating|
|to manage our existing relationship with you ||Fulfilling Contracts||n/a|
|To manage the products and services you have with us||Fulfilling Contracts, or consent||n/a|
|To keep you updated about our products and services||Fulfilling Contracts, or consent||n/a|
|To keep you updated about our products and services||Our legitimate interest, or consent||Keeping new/existing customers up to date with the products and services they have and with other products and services we offer |
|To develop and test new and existing products and analyse how customers use our products and services||Our legitimate interest, or consent||Identifying relevant customer groups and their needs and preferences, developing appropriate products and services, what we charge for them and who we provide them to, ensuring products are suitable for customers and meets expectation, so we can continue to improve our customer experience.|
|To develop and carry out marketing activities||Our legitimate interest, or consent||Keeping new/existing customers up to date with products and services they already have and with other relevant products and services we offer |
|To provide guidance and information about our products and services||Our legitimate interest, or consent||Being efficient as to how we fulfil our legal duties, ensuring customers have a clear understanding of the product they have or may have in the future|
|To improve, develop and manage our brands, products and services||Our legitimate interest, or consent||Developing products and services, looking at charges and who we will provide them to.|
|To be able to work with other companies that provide services to us and our customers||Fulfilling Contracts||n/a|
|To operate and provide lending and investment services||Fulfilling Contracts||n/a|
|To handle payments received from and provided to customers||Fulfilling Contracts||n/a|
|To apply charges, fees and interest due on customer accounts||Fulfilling Contracts||n/a|
|To recover and collect money that is owed to us||Fulfilling Contracts||n/a|
|To detect, investigate, report and seek to prevent financial crime||Our Legal duty||n/a|
|To control risk for us, and our customers||Our legitimate interest and our Legal duty||Developing products and services, looking at charges and who we will provide them to, Complying with regulations that apply to us and Monitoring and mitigating risk|
|Sharing relevant information in respect of sale of the company or any part of the business||Our legitimate interest||Complying with due diligence requirements and running the business efficiently|
|To obey laws and regulations that apply to us||Our Legal duty||n/a|
|To respond to complaints and look to resolve them||Our Legal duty||n/a|
|To run our business in an efficient and proper way||Our Legal duty||n/a|
|To exercise our rights set out in agreements or contracts||Fulfilling Contracts||n/a|
|Statistical analysis and research||Our legitimate interest||Developing products and services that promote responsible lending and promoting products to interested parties with similar needs and wants|
7. Automated Decisions
We sometimes use systems to make automated decisions
using the personal information we have from you and other sources. Automating decisions allows us to make consistent and efficient decisions regarding the products and services we offer.
These automated decisions can affect the products and services we may offer you
now or in the future, or the price that we charge you for them.
Below are details of the automated decisions we
make which are necessary for entering into, or performance of a contract:
|Automated Decision||What is automated|
|Pricing||Where you have requested a loan, we will decide what rate of interest to charge based on what we know about you from your application and other sources|
|Tailored Products & Services||We may place customers in or monitor certain customer groups- who have similar characteristics. We use this to learn about customer needs and wants so we are able to make better and more informed decisions. This also helps us tailor our products and services to our customers needs|
|Detecting Fraud||We use your personal information to monitor and assess if your account is being used or suspected to be used for fraud or money-laundering. We look for traits adopted by fraudsters or look for trends of activity which do not match your usual activity|
|Opening Accounts||We you apply for an account we will check that the product or service is suitable for you. We will also check that you meet the requirements to open and account or receive the product or service applied for. |
|Approving Credit||We may use an internal system to decide whether to lend money to you, if you submit a loan application. The information used is historic data.|
Credit scoring uses data from three sources:
- The loan application details submitted
- Credit Reference Agencies
- Data we may already hold
A credit score gives and overall assessment based on this. Kuflink uses this to help make responsible lending decisions. Credit scoring methods are tested and reviewed regularly to make sure that a fair and unbiased decision is provided consistently"
|Account Lifecycle Management||When you have a loan agreement with Kuflink, we will periodically asses the performance of your loan. Dependent upon the assessment outcome this may result in us making contact with you to further understand your current situation|
We will hold your personal information for as long
as you have a relationship with us, e.g., you have applied for a product or you are an existing customer of ours, and for a period of time after
our relationship ends e.g., your application was declined, you have closed your account. How long we hold your information for depends on the nature of our relationship, the type of
information and the purposes for which we hold it.
The information we will retain will be such that helps us to
- comply with legal and regulatory requirements, e.g.,
anti-money laundering laws and laws that require us to keep details of transactions
we have been party to (loan repayments, investor payments)
- establish, exercise and defend legal claims
- prevent and detect fraud
- pursue our or third party’s legitimate interest,
e.g., developing and improving credit risk models e.g., where you are a Kuflink borrower we will retain your
data for analysis and also provide it to credit reference agencies so they can
use it for the purposes outlined.
- deal with any complaints regarding our services
- ensure we do not send any marketing to people who
have opted out
- maintain business records for analysis and audit
your personal data
may share your information with any member of the Kuflink Group and with some
of our business partners, service providers and subcontractors in connection
with the performance of any contract we enter into with you or them.
may also disclose your information to third parties where you have consented
for us to do so, where we are under a legal, regulatory or professional
obligation to do so, where we need to enforce or apply our various terms,
policies and other agreements, or if it becomes necessary to protect the
rights, property or safety of Kuflink, our customers or any other person.
we merge, reorganise or transfer all or part of our business, we may disclose
information we hold about you to successors (and potential successors) of the
we refer any dispute between us to the ODR Platform http://ec.europa.eu/consumers/odr ,
and/or we agree to engage in any alternative dispute resolution (“ADR”)
procedure with you through the ODR Platform, then to the extent that your
personal data is relevant to the dispute we may disclose it to the European
Commission, as operator of the ODR Platform, and to any ADR provider appointed
to deal with the dispute.
rights as a data subject
You may have some or all of the following rights
dependent upon how and why your information was collected and how we are using
to Access - You may have a right to request access to
the personal information we hold about you (this is also known as a subject
to Rectification - You can request at any time that we update
and correct any out of date or inaccurate personal information we hold about you;
You can do this by contacting us at Hello@kuflink.com
to Erasure - In some circumstances you can request
that we remove all personal information we hold about you, if there is no need
for us to keep it; You can do this contacting us at Hello@kuflink.com
to Restrict Processing and Object to Processing -
If we process your data, you can request that we stop or restrict the
processing of your personal information;
Email preferences can be changed using the ‘Email Preferences link in ‘My
to Withdraw Consent – You can withdraw your consent at any time by
contacting Kuflink, once consent is received, Kuflink will stop processing your personal data and where consent is the lawful basis for us processing your personal data; and
to Data Portability - You can make a request for us to provide
personal information you have supplied to Kuflink to a third party.
There may be regulatory or legal reasons why we cannot satisfy
your requests, but we will advise you of this when a request is made.
For further information on each of these rights, including the
circumstances in which they apply, see the guidance from the UK Information
Commissioner’s Office (ICO).
personal data provided by you during registration onto the Platform, along with
details of your download history, can be accessed via ‘My Account’.
you wish to make a data subject access request, please do so in writing, sent
to the email or postal address shown below, clearly marking your correspondence
as a subject access request.
do not normally charge for subject access requests unless they are ‘manifestly
unfounded or excessive’ (e.g. repetitive). We will respond to your subject
access request within one month of receiving it. In the unlikely event that
your request is particularly complex, a further two months may be required but
we will keep you informed if this is the case.
use the following cookies:
Strictly necessary cookies: These are cookies that are required for the
operation of our website. They include, for example, cookies that enable you to
log into secure areas of our website. They do not gather information about you
that could be used for marketing purposes or remembering where you’ve been on the
Analytical/Performance cookies: They allow us to collect information about how
you use our website, such as, how you move around our website and if you
experience any errors. These cookies do not collect any information that could
identify you; all of the information collected is anonymous and is only used to
help us improve the way our website works, understand what interests our users
and measure how effective our advertising is.
Functionality cookies: These are used to recognise you when you return to our
website. This enables us to personalise our content for you, greet you by name
and remember your preferences and improve your visit.
this site and around the web that collect and use personal data (e.g. your IP
address) in order to select and deliver measurable personalised advertising
from this site and other advertisers in NextRoll's network, as well as to
analyse and understand your use of our websites using NextRoll's services.
similar technologies by NextRoll and its advertising partners.
select "Reject", NextRoll will not serve you personalised
advertising. You may still receive advertising that is not targeted or is
served by other third parties that are not affiliated with NextRoll.
"Allow" now, you have the right to withdraw your consent at anytime.
To manage NextRoll's partners and learn more, visit https://d.adroll.com/consent/choices.
cookies which are strictly necessary for the operation of the website will
expire when you leave the website. Other cookies may be more permanent or not
expire unless you actively delete them.
13.Credit Reference Agencies (CRAs) and Fraud
Prevention Agencies (FPAs)
carry out credit and/or identity checks when you apply for a product or
service. We use CRAs to help us with this.
If you use our products or services, from time to
time we may also search information that the CRAs have about you, to help us
manage those accounts.
To do this, we will supply your personal
information to CRAs and FPAs and they will give us information about you. This will include information about your financial situation and
financial history. CRAs and FPAs will give us publicly available information
about you (including information from the electoral register) and privately
held information which will include your credit history, your current financial
situation, financial history information and fraud prevention information.
When we use your information, and share it with
CRAs and FPAs, we do so as a necessary step to assess whether or not we can
enter into a contract with you. Where your loan application is approved and you
choose to enter into a loan through Kuflink, it will continue to be necessary
for us to carry out these checks from time to time to perform the contract we
have with you.
We will use the information that we receive from
CRAs and FPAs to:
1. Help us assess whether or not we think you
can afford to take out the requested loan and meet your loan obligations
2. Make sure that the offers we are able to
provide to you are fair and appropriate to your circumstances and check
the information that you have provided to us is accurate
3. Meet our legal obligations to help prevent
criminal activity, fraud and money laundering
4. Manage your account(s)
5. Trace and recover debts where we have been
unable to make contact with you via any other means that we hold your
information (i.e. phone, email, letter)
When CRAs receive a search from us they will place
a search footprint on your credit file that may be seen by other lenders and
other similar companies or organisations. When FPAs receive a search from us
they will keep a log of the searches that we have carried out but this will not
be shared with any CRAs.
If you are making a joint application, or tell us
that you have a spouse or financial associate, we will link your records
together, you should make them aware how their personal
information will be used by us, before you complete the application. In
addition, you should both also be aware that CRAs will also link your records
together and these links will remain on both of your files until an approved
request is received by the CRAs confirming that the financial relationship no
We will continue to exchange information about you
with CRAs and FPAs while you have a relationship with us. We will also inform
the CRAs once you have finished repaying a loan with us. If you borrow money
through Kuflink and do not make all your repayments in full and on time this
information will be shared with CRAs who will record that information as part
of your credit history. It is possible that the CRAs will then share this
information with other organisations who have a relationship with them.
If you give us false or inaccurate information or
if we suspect or identify fraud we will record this and will also pass this
information to FPAs and other organisations involved in crime and fraud
prevention, including law enforcement agencies.
We and other organisations may access and use this
information in order to prevent fraud, money laundering or other criminal
activity. If we, or a FPA, determine that you pose a fraud or money laundering
risk, we may refuse to provide our products and services you have requested, or
we may stop providing existing services to you.
Fraud prevention agencies can hold your personal
data for different periods of time, and if you are considered to pose a fraud
or money laundering risk, your data can be held for up to six years and may
result in other companies or organisations refusing to provide services,
financing or employment to you.
If you have any questions about this, please
contact us at firstname.lastname@example.org
The links below will provide you with further
- the identities of the CRAs
- their role as FPAs
- the information they hold about you
- the ways in which they use and share personal
- the length of time that they will hold on to your
- your data protection rights
14. Direct marketing
When you register with Kuflink we'll give you the
option to opt-out of receiving different categories of messages from us. These
categories relate to letting you know about new products, promoting
our existing products and general marketing.
We only send these messages if there is something
worthwhile to tell you about. If you don't want to receive these messages you
can log into your account and change your settings
We’ll still send you messages relating to Kuflink
products you have where this is necessary to provide you with a good service.
There also may be some messages that we're required by law or regulation to
send you even if you ask us not to.
15.1. To contact Kuflink about anything to do with your personal data and data protection, including to make a subject access request, please use the following details and we will respond as soon as possible:
Making a complaint and dispute resolution
We hope that we are able to resolve any query or
concern that you raise about our use of your information, so please get in
touch with us on the above details if you have any questions or issues with
If you are dissatisfied with any response you receive from us,
you may refer your complaint to the ICO. Find out more on