Any reference to “We” or “Us” in this Policy shall mean Thryft Limited. This Policy applies to www.thryft.gi (Site) which is owned and operated by Thryft Limited.
We are committed to protecting and respecting your privacy. We understand that your privacy is extremely important to you. As a result we have put in place a number of measures to ensure that any personal data we obtain from you is processed and maintained in accordance with the General Data Protection Regulation (EU Regulation 2016/679) (GDPR) and used only when it's appropriate to do so.
This Policy applies both while you have a loan from us and afterwards. Throughout this Policy “you” means the customer. This Policy is regularly reviewed to make sure that we continue to serve your privacy interests. We reserve the right to update this Policy, and any changes will be posted on our Site. We encourage you to periodically review this page for the latest information on our privacy practices. We are committed to keeping your personal data confidential and will only give it to others for the purposes set out in this Policy.
Information About Us
For the purpose of GDPR, we are Thryft Limited, a company incorporated and registered in Gibraltar whose registered office is at Suites 1 & 2, Newton House, 5 King’s Yard Lane, Gibraltar.
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Policy.
We recognise how important it is to protect and manage the information you share with us. We have implemented technology and security policies to protect personal data we hold about you. When you share data on our forms, that information is protected using secure Socket Layer Technology (SSL).
Despite our best endeavours to protect your personal data, you must be aware of the inherent security risks of providing information and dealing online over the internet. We cannot therefore guarantee that any data disclosed online is secure.
We try to meet and exceed industry standards on security and we are constantly monitoring internet developments to ensure our systems evolve as required.
Information we collect from you
GDPR defines personal data as ‘any information relating to an identified or identifiable natural person, 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.’
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, email address and telephone numbers.
• Financial Data includes income, bank account and payment card details.
• Transaction Data includes details about payments to and from you.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Site.
• Profile Data includes your username and password, payments made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our Site, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of our Site. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We may record and/or monitor calls for quality checks and staff training. Such recordings may also be used to help us combat fraud.
We may also keep details of the following:
• Any phone number(s) that you call us from and use them to contact you;
• Any details of when you contact us and when we contact you; and
• Any information which we reasonably need to operate your account, make decisions about you or fulfil our legal and regulatory obligations.
References to personal data include all of the information above whether obtained from you, from a Credit Reference Agency or Fraud Prevention Agency, from the internet or from any other source.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with a loan). In this case, we may have to cancel a loan agreement you have with us or reject an application but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in application forms or by corresponding with us by post, phone, email, free chat or Whatsapp or otherwise. This includes personal data you provide when you:
• apply for a loan;
• create an account on our Site;
• subscribe to any of our publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
• Technical Data from the following parties:
(a) analytics providers (such as Google) based inside OR outside the EU;
(b) advertising networks based inside OR outside the EU; and
(c) search information providers based inside OR outside the EU.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside OR outside the EU.
• Identity and Contact Data from data brokers or aggregators based inside OR outside the EU.
• Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
Uses made of the information
We will use your information to provide our services, to prevent and detect fraud, money laundering and other improper activities, carry out regulatory checks and meet our obligations to any relevant regulatory authority, and to develop and improve our services to you and other customers and to collect payments and resolve disputes.
We may use information held about you for the following:
• To register you as a new customer;
• To search Credit Reference Agencies’ and Fraud Prevention Agencies’ records (including information from overseas);
• To process an application and to make, or assist in making, credit decisions about you, assess lending and insurance risks, and to check the details that you have let us and others have;
• To operate and manage our relationship with you and your account and manage any application, agreement or correspondence you may have with us;
• To carry out, monitor and analyse our business;
• To contact you by Whatsapp, chat, SMS, phone, e-mail or otherwise about an enquiry or our products and services, unless you tell us that you prefer not to receive marketing;
• To identify, prevent, detect or tackle fraud, money laundering, terrorism and other crimes;
• To form a view of you as an individual and to identify, develop or improve products, that may be of interest to you;
• To carry out market research, business and statistical analysis;
• To provide information to independent external bodies such as governmental departments and agencies, universities and similar to carry out research;
• To carry out audits and perform other administrative and operational purposes including the testing of systems;
• To trace your whereabouts and to recover any debt you owe us;
• To comply with our legal and regulatory obligations;
• To notify you about changes to our service, prize draws, competitions or to complete a review or a survey;
• To make suggestions and recommendations to you about goods or services that may be of interest to you;
• To ensure that our Site is up to date and its content is presented in the most effective manner for you and for your computer.
Your information may also be used for other purposes for which you give your permission, or where we are permitted to do so by law, or it is in the public interest to disclose the information or is otherwise permitted under GDPR.
We use systems to make automated decisions about you to help us make sure our decisions are quick, fair, efficient and correct, based on what we know.
Automated decisions can affect the products we may offer you now or in the future. They are based on personal information that we have or that we are allowed to collect from others.
We use a system to decide whether to lend money to you when you apply for a loan or top up loan. The system will use information from your application form and data we may already hold about you, including what we have collected from any previous loans you have had with us.
We may also use a system that helps us detect fraud and money laundering.
We may use any data we already hold about you and your payment history with us to help us make decisions on how we should lend to people in the future.
Disclosure of your information
We will keep your personal data confidential and only share it with others for the purposes explained in this Policy. We have trusted relationships with carefully selected third parties who perform services on our behalf.
We may share your personal data with selected third parties for the following reasons:
• To our affiliated companies (some of which may be located outside Gibraltar), agents and approved third parties to carry out services for us that help us operate our lending business;
• To facilitate the processing and collection of payments due from you, we may also share your personal data with third party payment processing service providers, including debt collections agencies and tracing agents. These companies are authorized to use your personal data only as necessary to provide these services to us;
• To protect us, our group of affiliated companies or others, we may share your information with third parties when we believe it is necessary to comply with the law, such as to comply with a subpoena, or similar legal process or protect our or another person’s rights, property, or safety. This includes exchanging information with third parties (such as other lenders, law enforcement agencies and regulatory authorities) to protect against fraud and reduce credit risks; and
• To regulatory and governmental authorities ombudsmen, or other authorities, including tax authorities, including those overseas, where we are requested by them to do so.
If there is (or is to be) any change in ownership of our business or assets then we may wish to share your personal data so that the new (prospective) owners may continue to operate our business effectively and continue to provide services to our customers. This may include new shareholders or any organization that might take an assignment or transfer of any agreements we have entered into with our customers.
If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal data, as well as any choices you may have regarding your personal data.
Transfer of information
We may transfer your personal data abroad to other countries outside the European Economic Area (EEA). If we do so, we will ensure the information is held securely to standards at least as good as those in Gibraltar and only used for the purposes set out in this Policy.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
How long do we keep your information?
Generally, we will keep information that is necessary to enable us to provide you with a service that you have requested through the Site for as long as it takes us to provide that service.
If you have asked that we do not use your details for marketing purposes, we may still need to keep them to ensure our systems reflect your preferences.
We will generally keep records of any transactions you enter into with us for a minimum of six years from the end of the relationship, so that we can respond to any complaints or disputes that may arise in that period. Otherwise we will keep information as long as necessary to comply with the law, and where appropriate for legitimate business needs.
We periodically review data we hold on you and erase or anonymise it when we no longer need it.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at firstname.lastname@example.org.
If we need to use your data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Third party links and marketing
Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check their policies before you submit any personal data to these websites.
We will get your express opt-in consent before we share your personal data with any company for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into your USER ACCOUNT and checking or unchecking the relevant box to adjust your marketing preference or by contacting us at any time at email@example.com.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a loan application or other recorded communication.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or successfully applied for a loan from us and in each case you have not opted out of receiving that marketing.
Social media features
Access to information
GDPR gives you the right to access information held about you. Your right of access can be exercised in accordance with GDPR. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee for any access request if this is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. These can be made by writing to firstname.lastname@example.org.
To ensure that your information is accurate and up to date you may ask us to correct or remove any information that you think is inaccurate.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We may display personal testimonials of our satisfied customers on our Site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to provide a testimonial, or update or delete an existing one, please email us at email@example.com.
Your legal rights
Under certain circumstances, you have rights under GDPR in relation to your personal data. You have the right to:
• 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.
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org.
We reserve the right to amend and update this Policy from time to time. We encourage you to periodically review this page for the latest information on our privacy practices.
Any changes we make to this Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.