Who we are
The aqua credit cards are underwritten and managed by SAV Credit Limited, and issued and administered by Progressive Credit Limited.
Where we obtain your information
Your personal information will be shared within the SAV Group so that we and other companies in our Group can look after your relationship with us. By sharing this information it enables us to better understand your needs, run your accounts and provide products in the efficient way that you expect. This will include information you provide when you apply to us, and any additional information provided by you or others in various ways, including:
(a) in applications, emails and letters, during telephone calls, when registering for services, in customer surveys, when you participate in competitions and promotions, through SAV websites, and during financial reviews and interviews;
(b) from analysis (for example, the amount frequency, location, origin, and recipient) of your payments and other transactions, and your use of services involving other SAV Group companies and what they know from operating your account; and
(c) information SAV Group companies receive from each other, from our business partners, and from other organisations such as credit reference agencies and fraud prevention agencies.
How we share your information
We may share the personal information we hold about you across the SAV Group for the following administrative activities:
a) providing you with products and services and notifying you about either important changes or developments to the features and operation of those products and services;
b) responding to your enquiries and complaints;
c) administering offers, competitions, and promotions;
d) undertaking financial reviews;
e) updating, consolidating, and improving the accuracy of our records;
f) undertaking transactional analysis;
g) arrears and debt recovery activities;
h) testing new systems and checking upgrades to existing systems;
i) crime detection, prevention, and prosecution;
j) evaluating the effectiveness of marketing, and for market research and training;
k) customer modelling, statistical and trend analysis, with the aim of developing and improving products and services;
l) assessing lending risks;
m) managing your relationship with us.
By sharing this information it enables us, and other companies in the SAV Group, to better understand your needs and run your accounts in the efficient way that you expect. Your data may also be used for other purposes for which you give your specific permission, or, in very limited circumstances, when required by law or where permitted under the terms of the Data Protection Act 1998.
When we may share your information
We will treat your personal information as private and confidential, but may share it within the SAV Group or disclose it outside the SAV Group:
(b) if you consent;
(c) if needed by our agents, advisers or others involved in running accounts and services for you or collecting what you owe SAV Group companies;
(d) if needed by subcontractors to help us manage your records;
(e) if HM Revenue & Customs or other authorities require it;
(f) if the law, regulatory bodies, or the public interest permits or requires it;
(g) if required by us or others to investigate or prevent crime;
(h) if needed by market research companies to assist us in providing better products and services for you; or
(i) to any other parties connected with your account (i.e. additional cardholders).
We will always ensure your information remains safe and secure.
Sharing your information with other companies
If you were ‘introduced’ to us by a third party and/or have a relationship with or are supporting one of our affinity partners (E.g. a charity credit card account), we will give them your contact details and sufficient information about you to help with their accounting and administration. Introducers or affinity partners may use these details to contact you about products and services unless you have asked them not to do so.
Using your information to help prevent terrorism and crime
The Government requires us to screen applications that are made to us to ensure we are complying with the international fight against terrorism and other criminal activities. As a result of this we may need to disclose information to government bodies.
Sharing your information to assist with asset buying or selling
SAV Group of companies may in the future wish to sell, transfer or merge part or all of their business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it. If so, they may disclose your personal information to a potential buyer, transferee, or merger partner or seller and their advisers so long as they agree to keep it confidential and to use it only to consider the possible transaction. If the transaction goes ahead, the buyers, transferee or merger partner may use or disclose your personal information in the same way as set out in this notice.
Sharing personal information between joint applicants
If you authorise another person to be an additional cardholder, this will mean that your personal data will be shared with the other cardholder on the account. For example, transactions made by you will be seen by your additional card holder and vice versa.
How we manage sensitive personal information
The Data Protection Act defines certain information relating to your racial or ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, sexual life, criminal proceedings and offences as ‘sensitive’ data. From time to time you may need to provide sensitive data to us in order to enable us to respond to a query from you or to deliver a service to you. We will only use this information to provide the service you require. We may share sensitive information with other parts of the group and our subcontractors to keep your records up to date.
Using companies to process your information outside the EEA
All countries in the European Economic Area (EEA), which includes the UK, have similar standards of legal protection for your personal information. We may run your accounts and provide other services from centres outside the EEA (such as the USA and India) that do not have the same standard of data protection laws as the UK. If so, we will require your personal information to be protected to at least UK standards. We may process payments through other financial institutions such as banks and the worldwide payments system operated by the SWIFT organisation if, for example, you make a CHAPS payment or a foreign payment. Those external organisations may process and store your personal information abroad and may have to disclose it to foreign authorities to help them in their fight against crime and terrorism. If these are based outside the EEA, your personal information may not be protected to standards similar to those in the UK.
Using credit scoring
When you apply for credit, an automated system known as credit scoring may be used when considering whether to agree to the borrowing. It is a method of assessing your likely conduct of an account based on a range of data, including the conduct of previous similar accounts. It is a system widely used by credit providers to help make fair and informed decisions on lending. Credit scoring takes account of information from three sources - the information you provide on your application, information provided by credit reference agencies and information that may already be held about you by companies in the SAV Group. A credit scoring system will consider information from these sources, to make an overall assessment of your application. Click here for a more detailed guide to credit scoring and how credit reference agencies and others will use your credit-related information. The credit scoring methods used are regularly tested to ensure they remain fair, effective and unbiased.
Using a credit scoring system helps our Group companies to lend responsibly.
If you submit an application and it is declined through this automated process, you can contact us within 21 days to have the decision reconsidered. You also have the right to ask that the decision is not made based solely using a credit scoring system.
Credit Reference Agencies we use are
Call Credit Consumer Services Team
PO Box 491
Tel 0870 060 1414*
Equifax PLC Credit File Advice Centre
PO Box 3001
Tel 0870 010 0583*
Experian Credit Report Services Experian Ltd
PO Box 1135
Tel 0870 241 6212*
Using Fraud Prevention Agencies
We have systems that protect our customers and ourselves against fraud and other crime. Customer information can be used to prevent crime and trace those responsible. We will share your personal information from your application with fraud prevention agencies. If false or inaccurate information is provided and fraud is identified, details of this fraud will be passed to these agencies. Law enforcement agencies may access and use this information. We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:
- Checking details on applications for credit and credit related or other facilities.
- Managing credit and credit related accounts or facilities.
- Recovering debt.
- Checking details on proposals and claims for all types of insurance.
- Checking details of job applicants and employees.
We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.
How we check your identity
We may ask you to provide physical forms of identity verification when you open your account. Alternatively, we may search credit reference agency files to verify your identity when assessing your application. The agency also gives us other details and information from the Electoral Register to verify your identity. The agency keeps a record of our search, whether or not your application proceeds. Our search is not seen or used by lenders to assess your ability to obtain credit.
Using your Email address for service contact
Making sure we deliver excellent customer service is very important to us and to do this various methods of communication may be used to keep you updated about your account. Most of the time we communicate by telephone or post, but we recognise that email is becoming a more popular process. If we decide to use email to contact you, we will only do this if we have ensured that using email will not put your information at risk, or, if you have requested we email you, that we have explained the risks of sending an "insecure" email and that you are happy to accept that risk. In addition you may wish to choose a channel of communication that suits you when you need to contact us. If you need to email us, we recommend you check their website to see if a secure email facility exists so that your email can be sent securely. If you send us emails in other ways, such as from your personal account, then remember that the message may not be secure and there is a risk that it could be intercepted. If you choose to send an “insecure” email, please keep the amount of confidential information you include to a minimum. With some of our products we offer a number of communication update services via SMS. If you have signed up to this service, we may send you text messages containing administrative information about your relationship with us. You can ask us to stop sending these messages at any time. Additionally, in extraordinary circumstances (such as natural disaster or civil unrest) we may also send you updates by text message or email when we consider it to be appropriate.
Recording phone calls
We may monitor or record phone calls with you in case we need to check we have carried out your instructions correctly, to resolve queries or issues, for regulatory purposes, to help improve our quality of service, and to help detect or prevent fraud or other crimes. Conversations may also be monitored for staff training purposes.
Using information on social networking sites
As part of our ongoing commitment to understanding our customers better, we may research comments and opinions made public on social networking sites such as Twitter and Facebook.
Obtaining a copy of your information
Under the Data Protection Act you have the right of access to your personal data. The Act allows us to charge a fee of £10 for this service. If anything is inaccurate or incorrect, please let us know and we will correct it. For further details on how to request a copy of your information, please contact us on 0845 601 0436*.
Using your personal information to contact you about products and services
Unless you have asked us not to, we and other SAV Group companies may contact you by mail, telephone, email or text message about products and services available from the SAV Group. In addition we may also contact you about products and services from selected companies outside the SAV Group, which we believe may be of interest to you or benefit you financially. We promise not to contact you about everything - only if we think it could be appropriate and relevant to you, such as preferential savings opportunities, account upgrades or special offers. This contact may continue after your relationship with us ends.
You may opt out of receiving this information at any time by calling us or writing to us using the contact details below or contacting your local branch. We will not provide information about you to companies outside our group to use for their own marketing purposes.
We try to limit our customer contact programme to acceptable levels, but if you wish to exercise your right to opt out, simply contact our customer services on 0845 601 0436*.
Organisations must lodge a notification with the Information Commissioner describing the purposes for which they process personal information. The details are publicly available from the Information Commissioner's office and you can view ours notification at: [http://www.ico.gov.uk/ESDWebPages/search.asp].
Changes to Privacy Notice
We keep our privacy notice under regular review and we will reflect any updates within this notice. This privacy notice was last updated in January 2012.