Privacy Policy​

Our firm information

By ‘We’, Our or ‘Us’, we refer to our firm, Social Money Limited which uses the trading name ‘Dopple’. We are Registered in England and Wales at the Registered Address: 2nd Floor, St Johns House, Barrington Road, Altrincham, Greater Manchester, United Kingdom, WA14 1JY.

 

By “You” we mean you, the user of this website and the individual/customer that may seek to access, or has accessed, our
services. We are Authorised and Regulated by the Financial Conduct Authority. Our Firm Reference Number is 675283 and you can check our registration by going to the FCA’s register at
https://register.fca.org.uk/s/ For the purposes of the Data Protection Act 2018 (‘DPA’), we are the
‘Data Controller’ (i.e. the company who is responsible for, and controls the processing of, your personal data).

 

Information commissioners office (ICO) registration information

 

We are registered with the Information Commissioner’s Office, Registration Number: ZA026178

 

Our contact information

website, www.dopplepay.com
Telephone: 0161 676 9595
Email: support@dopplepay.com
In-person or by Post: 2nd Floor, St Johns House, Barrington Road, Altrincham, Greater Manchester, UK, WA14 1JY

Purpose of this policy

Your privacy is very important to us, and we set out in this Privacy Policy how we process any personal data collected from you or provided by you. If you access any other websites which may be linked to our websites, they are not covered by this Policy. We advise you to check the appropriate privacy policy when accessing linked websites. We take the privacy of our website users seriously and we are committed to protecting your privacy in compliance with United Kingdom (UK) data protection laws and regulations, including from the General Data Protection Regulation (EU 2016/679) and the Data Protection Act 2018 (‘Data Protection laws’). This Privacy Policy explains what personal data is collected about you via the website and our app and what we do with that personal data. We provide this Privacy Policy to make you aware of our practices in connection with your privacy and of the choices you can make about the way your personal data is collected and used by us.

Purposes for processing personal data

‘Personal Data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. We will process your data for the following purposes:

1. To provide you with requested services, including communications regarding requested services.
2. To record any information required for the tailoring of our services in consideration of any of your needs and requirements.
3. To improve our services and customise our website and its content to your particular preferences.
4. To comply with any laws or regulations to which we are subject.
5. Where you consent, for marketing purposes.

Lawful basis for processing

Data Protection Laws require that we meet certain lawful grounds before we are allowed to use your personal data in the manner described in this Privacy Policy and that we will explain these legal grounds to you. We take our responsibilities under Data Protection Laws seriously, including meeting these conditions. We rely on the following lawful bases for processing:

1. Contract (i.e. where we need to process personal data to deliver a contractual service to a customer or because a customer has asked that we do something before entering into a contract).
2. Consent (i.e. where we have asked whether you wish to permit us to process data in a certain way and you have told us that you allow us to do so).
3. Legal obligation (i.e. where we need to process the personal data to comply with a common law or statutory obligation).

 

Use of special category data

We will obtain personal data when you contact us for any reason or proceed with our services. In certain circumstances, we may hold special category data (also known as sensitive personal data). Any special category data held will be treated with the strictest of confidence and will be held purely based on your explicit consent to aid us in providing the best service to you. If you do not provide your explicit consent relating to any impairment or vulnerability, the information will not be recorded and will also not be disclosed to any third parties.

Data we collect, control and process

Direct interactions

You may provide us with your identity, contact and financial data by completing our application form. This includes the personal data you provide when you:
• Engage our services; or
• Provide us with feedback.

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Third parties or publicly available sources

We may also collect personal data about you from third party sources as follow:

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Data Collected.  Personal Identity Information. Personal Credit Rating. Financial Information. Technical Information. 

Examples of Data Collected.  Name, surname, DOB, country, mobile number, employment status. Your Credit Rating. Income, debt level, credit limit, account numbers, bank statements, adverse financial history including CCJs. Internet Protocol (IP) address, browser type and version,time zone setting and location, browser plug-in types and versions, operating systems and platform. 

Gathered From.  Application form. Credit Ref Agencies: Experian, Equifax, Transunion. Cookies .

When we might have obtained it.  Generated as a result of providing our services to you. Obtained as part of the lending application to assess your creditworthiness and affordability. From you when using our websites and in accordance with our Cookie Policy. 

 

How we handle personal data

We will only use the personal data you provide to us as described in this Privacy Policy, including any supplemental privacy information, as set out above. We will store and process your personal data on our computers and secure cloud servers.

We will observe the rights granted to you under applicable Data Protection Laws, as set out below, and will ensure that queries relating to privacy issues are dealt with promptly and in a transparent manner. We will only collect and process your personal data where we have lawful grounds to do so. We will update our records if you inform us that your details have
changed. Please tell us (see contact details above) as soon as possible about this. We will update our records promptly once we are satisfied that the new information (such as your new address or contact details) is accurate.

 

Recipients of personal data

In the course of providing our service, we may need to disclose personal data to third parties, as follows:
1. Our panel of lenders.
2. Credit reference agencies.
3. Third party providers of services to us, including our hosting services provider, acting as processors.
4. HM Revenue & Customs, the Financial Conduct Authority (FCA), The Information Commissioner’s Office (ICO), other regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.
5. Accountants, solicitors, compliance consultants and similar, acting as processors and based in the United Kingdom who
require the reporting of processing activities in certain legal and compliance circumstances.
6. Third parties to whom we may choose to sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change in these circumstances occurs, your personal data will be used in the same way as set out in this Privacy Policy. We may also disclose your personal data to other companies in our
group of companies.

Google analytics

Google Analytics is a service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyse how users use our website and our mobile site. The information generated by these cookies (including your truncated IP address) is transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your, and other users’, use of our website. Compiling reports for us on website activity and providing
other services relating to website activity and internet usage. The Google Analytics advertising features we use, and the insights they provide are:
AdWords Remarketing — uses behaviour, demographic, and interest data to identify users who are likely to convert, and then allows you to target those users with remarketing campaigns through Google Ads.
Demographics and Interests Reporting — provides insight into the age, gender, and purchase interests of users, which you can use to better target your advertisements. Google Display Network (GDN) Impression Reporting — measures the
impact of unclicked GDN Display ad impressions on conversions and site behaviour.
Please note that Google receives your truncated IP address. This is sufficient for Google to identify (approximately) the country from which you are visiting our sites or accessing our website but is not sufficient to identify you, or your computer or mobile device, individually. You can find more information here, including a link to Google’s privacy policy.
To opt-out of analysis by Google Analytics on our website and other websites, please visit http://tools.google.com/dlpage/gaoptout.

International transferes

We currently do not transfer data outside the United Kingdom (UK). Personal Data shared with our Recipients of Personal Data (see above), may transfer personal data outside the UK. Should this be the case, the international transfer will be made in accordance with appropriate and documented safeguards.

Your rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data:
•Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a
copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate
data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good
reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you
have successfully exercised your right to object to processing (see below), where we may have processed your information
unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not
always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable,
at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and
there is something about your particular situation which makes you want to object to processing on this ground as you feel it
impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal
data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to
process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your
personal data in the following scenarios:

(a) if you want us to establish the data's accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend
legal claims; or
(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to
use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not
affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may
not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your
consent. You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can exercise any of these rights at any time by contacting us at support@dopplepay.com.

 

How do we respond to your request?

We must act on request without undue delay and at the latest within one month of receipt. This is calculated as beginning from the day following receipt of the request until the corresponding calendar data the following month. We may request evidence of your identity, however, this will be proportionate to the request itself and if we have doubts of the authenticity of identification.

As you have the right to be informed, we will always ensure you are notified within one month of receiving the request. Please note, we may extend the time to respond by a further two months if the request is complex or you have made multiple requests and we will provide you with an explanation for this. If you make a request via electronic means, we will provide the
information in a commonly used electronic format unless you have specified otherwise.

 

Will it cost you anything?

For the vast majority of requests, we cannot charge you a fee. Where the request is manifestly unfounded or excessive, we may charge a reasonable fee to cover the administrative costs of complying with the request. This also applies in the event that you request further additional copies of data following your initial request. This will again be charged as an administrative cost.

 

Data retention

How long will we hold your personal data?

We will only retain your personal data for as long as is necessary to fulfil our obligations under the provision of our service
as well as any purposes necessary to satisfy any legal, accounting or reporting requirements.

We will take steps with a view to permanently deleting, destroying or anonymising your personal data (which means that
we are no longer able to identify you from it) when it is no longer necessary for its purpose.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of
the personal data, the potential risk, harm of unauthorised use or disclosure of your personal data, the purposes for which
we process your personal data and whether we can achieve those purposes through other means, including applicable
legal requirements.

Details of retention periods for different aspects of your personal data are available upon request. By law, we have
to keep certain information about our customers and this data will be held solely and securely for those legal purposes.

Cookies

A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website. Cookies are used by many websites and can do a number of things such as remembering your preferences, recording what you have put in your shopping basket, and counting the volume of people accessing the website. We do use cookies. For more information on our use of cookies, please see our Cookie Policy.

Data security

We are committed to ensuring the security of your personal data. In accordance with our obligations under Data Protection Laws, to prevent unauthorised access to your personal data, maintain data accuracy, and ensure the appropriate use of your personal data, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the personal data we collect online. However, you acknowledge that, unfortunately, the transmission of information via the internet, including the online enquiry forms you submit to us and/or any information provided on Webchat, is not
completely secure. We cannot guarantee the security of your data transmitted to us, so any transmission (i.e. your sending of the personal data to us) is at your own risk. Once we have received your personal data, we will use the steps detailed above to protect it.

Customer feedback and complaints

If you are not happy with the way in which your personal data is held or processed by us, or if you are not satisfied with our handling of any requests by you in relation to your rights to any automated profiling that we carry out, our Data Protection Officer would be happy to help. You can contact our Data Protection Officer at dpo@dopplepay.com
Alternatively, you have the right to lodge a complaint to the supervisory authority, the Information Commissioner’s Office (ICO) by calling 0303 123 1113. The ICO is the UK’s independent body set up to uphold information rights. You can find out more about the ICO on its website (www.ico.org.uk/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. If you would like to make a
complaint, see our Complaint Policy <here>.

Changes to our privacy policy

Any changes to our Privacy Policy in the future will be posted to our sites. This Privacy Policy was last updated 18/04/2024.