Membership Terms and Conditions

About us

CLEVR and CLEVR Money are trading names of Blackpool, Fylde & Wyre Credit Union Limited.

When we say “we”, “us” or “our” in this privacy notice, we mean Blackpool, Fylde & Wyre Credit Union Limited.

We’re responsible for deciding how and why your personal information is collected and used. In data protection terms, this makes us the data controller.

 

What this notice is about

This notice explains what personal information we collect, where it comes from, how we use it, who we share it with, how long we keep it and the rights you have.

It applies when you apply for or use one of our products or services, visit our website, use our app, contact us or otherwise deal with us.

It covers current, former and prospective members, savings and loan applicants, Junior Saver account holders and their parents or guardians, beneficiaries, authorised third parties (such as power of attorney), website and app users, complainants, and anyone else whose information we receive through our work.

We use a separate privacy notice for our workforce.

 

The information we collect

The information we collect depends on the product or service you use and what you’re asking us to do.

 

Information that identifies you

This includes your name, previous names, date of birth, current and previous addresses, contact details, identification documents, photograph, signature, nationality and residency information including tax residency and identification number.

We may also collect information needed to confirm that you meet our membership eligibility requirements.

 

Information about your membership and accounts

This includes your membership number, applications, savings accounts, account balances, transactions, deposits, withdrawals, payments, beneficiaries and the products you hold with us.

 

Financial and lending information

This includes your bank details, income, expenditure, existing borrowing, financial commitments, employment status, benefit income, requested loan amount, repayment term, affordability information, credit history, arrears, defaults, court judgements insolvency information and repayment history.

It also includes information about previous applications, accounts or loans you’ve had with us.

 

Payroll and benefit information

Where a deduction method is used to deposit into your account or repay a debt through payroll or benefit payments, we may collect your employer’s details, payroll number, income, deduction information, benefit payment details.

 

Open banking information

Where you choose to connect a bank account, we may receive account details, balances, transactions, income, regular payments, spending, borrowing and other information from the accounts and period you authorise.

 

Information you give us when we communicate

This includes emails, app messages, letters, complaints, customer service requests, feedback, survey responses and notes or records relating to our contact with you.

 

Information about vulnerability or support needs

You may tell us about a health condition, disability, accessibility requirement, financial vulnerability or other personal circumstances.

We’ll only use this information where it is relevant, for example to provide support, make reasonable adjustments or deal with your account, application, complaint or arrears appropriately. We might ask for evidence to support any disclosures.

 

Fraud, identity and compliance information

This includes identity verification results, fraud indicators, sanctions and politically exposed person screening results, suspected unlawful activity, information about the source of funds and records relating to investigations or regulatory matters.

 

Information about your device and use of our services

When you use our website, app or online services, we may collect your IP address, device and browser details, login information, authentication records, app activity, website activity, cookie identifiers and security information.

 

Marketing information

This includes your communication preferences, consent records and information about whether you’ve opened or interacted with a marketing communication.

 

Where your information comes from

Most of the information we use comes directly from you, including information you enter into an application, send through our app or provide when you contact us.

We may also receive information from credit reference agencies, identity and fraud prevention services, sanctions screening providers, open banking providers, banks and payment providers, employers and payroll teams, government departments, benefit payment services, debt advisers, authorised representatives, courts, insolvency practitioners, debt recovery services, regulators and law enforcement agencies.

We may use information from public records, such as the electoral register, insolvency records and court records. We may also use information we already hold about a previous application, account or relationship with you.

We may also use public details from your social media profiles.

 

When you need to provide information

Some information is optional. Other information is needed so that we can confirm your identity, check your eligibility, meet our legal obligations, consider an application, open and manage an account, process a payment or protect our services.

We’ll make it clear where information is required.

If you don’t provide information we reasonably need, we may not be able to open or operate an account, process an application or transaction, or provide the product or service you’ve asked for.

 

How we use your information

We need a lawful reason to use personal data. The reason depends on what we’re using it for.

 

Applications, memberships and accounts

We use your information to consider applications, confirm eligibility, open and operate your membership, manage savings and loans, process deposits and withdrawals, manage payments and close accounts.

We usually do this because it is necessary before entering into an agreement with you, to perform our agreement with you or to meet a legal obligation.

 

Lending and affordability

We use information about your finances, credit history, income, expenditure, existing commitments and previous account performance to assess eligibility, affordability, creditworthiness and lending risk.

We do this to consider your application, manage our agreement with you and support our legitimate interests in making responsible lending decisions and protecting members’ money.

 

Identity, fraud and financial crime

We use your information to verify your identity, prevent fraud, carry out anti-money laundering checks, screen for sanctions and politically exposed persons, investigate suspicious activity and keep our accounts and systems secure.

We usually do this because the law requires it or because we have a legitimate interest in preventing crime, protecting our members and preventing misuse of our services.

 

Running and protecting our services

We use personal information to authenticate users, secure accounts, investigate technical problems, monitor system performance, prevent unauthorised access and maintain reliable digital services.

We do this to perform our agreement with you, meet legal and regulatory requirements and support our legitimate interest in operating safe and secure services.

 

Communicating with you

We use your contact information to send account updates, application decisions, statements, payment information, security messages, changes to our services and other important information.

We may also use it to respond to questions, customer service requests, complaints and requests to exercise data protection rights.

Depending on the communication, we rely on our agreement with you, a legal obligation or our legitimate interests in managing our services and responding properly.

 

Arrears and recovering money

Where money is owed to us, we may use information to contact you, manage arrears, process payment arrangements, trace customers, recover debts and take or defend legal action, or instruct solicitors to act on our behalf.

We do this under our agreement with you, our legitimate interests in recovering money owed to the credit union and, where relevant, to establish, exercise or defend legal claims.

 

Governance, risk and compliance

We use relevant information to manage complaints, incidents, risks, controls, investigations, internal and external audits, regulatory reporting, supplier oversight and our wider legal and regulatory responsibilities.

We do this to meet legal obligations and because we have a legitimate interest in running a well-managed, accountable and compliant financial services business.

 

Improving what we do

We analyse how people use our products, app, website and services so that we can understand performance, fix problems, improve customer journeys and develop products.

We use anonymised or aggregated information where reasonably possible. Where we use identifiable information, we normally rely on our legitimate interests. We ask for consent where this is required, including for certain cookies and similar technologies.

 

Marketing

We may send you marketing about CLEVR Money products, services, news and events where you have agreed to receive it.

You can opt out at any time. This will not stop important service or account messages, and you may still see general advertising that is not specifically aimed or tailored to you.

 

Our legitimate interests

Where we rely on legitimate interests, we consider why the processing is needed and whether it could have an unfair effect on you.

Our legitimate interests include protecting members’ savings, making responsible lending decisions, preventing fraud and financial crime, recovering money owed to us, improving our services, maintaining secure systems, handling complaints, managing suppliers and risks, exercising legal rights and operating an efficient and sustainable credit union.

We won’t rely on our legitimate interests where your rights and interests clearly outweigh ours.

 

Sensitive information

Some information is treated as particularly sensitive under data protection law. This is known as special category information and includes information about health, disability, race or ethnic origin, religion, political opinions, trade union membership, genetics, biometrics, sex life and sexual orientation.

We’re most likely to use health, disability or vulnerability information where it helps us support you, communicate appropriately, make reasonable adjustments, understand your circumstances, protect your wellbeing or manage an application, account, complaint or debt fairly.

Where we use this information, we will make sure that it is processed in line with the higher standards required, compared to non-special category data.

We may also process information relating to actual or suspected criminal offences for fraud prevention, anti-money laundering, regulatory compliance and legal claims.

We only use this information where the law allows us to and we apply additional safeguards where required.

 

Credit reference and fraud prevention agencies

When you apply for any product from us, we may provide information to credit reference agencies and receive information from them. We may also provide information to credit reference agencies and receive information from them, from time to time as part of our processes of checking our data is current and to verify details.

We currently use TransUnion for credit reference and identity services.

Information received may include your name, previous names and aliases, current and previous addresses, bank account ownership, credit history, existing borrowing, repayment history, arrears, defaults, insolvencies, court records, address history, electoral register information, financial associations and fraud indicators.

A credit application search may be recorded on your credit file if you apply for credit from us, whether or not your application is accepted.

We may continue to exchange information with credit reference agencies while you have a loan or account with us. This may include your name, address, date of birth, balances, repayments, arrears, defaults, settlements and account closure information.

Credit reference agencies use and share information under their own privacy notices. More information is available in the Credit Reference Agency Information Notice on TransUnion’s website.

We may also use identity and fraud prevention services. Information showing a fraud or elevated risk indicators may affect whether we provide, restrict or continue a product or service.

 

Open banking

Where you choose to use open banking, we use an authorised open banking provider, to connect securely to the bank accounts you select.

Depending on the permission you provide, we may receive account details, balances, transaction history, income, spending, regular payments, overdraft arrangements and existing financial commitments.

We may use this information to verify what you’ve told us, assess income and expenditure, consider affordability and lending risk, identify possible fraud and manage an application or account. We may also use artificial intelligence via the service to analyse the data and make predictions about future financial patterns.

You’ll need to give permission through your bank before any information can be accessed. Access is limited to the accounts, information and period you authorise.

Your permission to connect your bank account is separate from our lawful basis for using the information once we receive it. We’ll usually rely on taking steps before entering into an agreement, performing our agreement with you and our legitimate interests in responsible lending and fraud prevention.

Our open banking providers and your bank may also use personal information under their own privacy notices.

 

Automated decisions

We use automated systems and rules to help us work quickly, consistently and securely.

These systems may match application details against records we already hold, confirm membership or product eligibility, verify identity, identify possible fraud, analyse credit reference or open banking information, assess affordability, consider previous account performance, apply product rules and decide whether an application should be accepted, referred, or declined.

The information used may include information you provide, information about previous applications or accounts, repayment history, credit reference information, open banking information, identity checks, fraud indicators and our product or risk rules.

Some decisions may be made entirely by automated means and may have a legal or similarly significant effect on you.

Where this happens, you can ask us for information about the decision, provide more information, make representations, ask for meaningful human involvement and contest the outcome.

A human review checks whether the automated process worked correctly and whether the information used was accurate. It does not guarantee that the commercial or lending decision will change.

You can request a review by emailing hello@clevr.money

We don’t use special category information to make significant automated decisions unless this is permitted by law and additional safeguards are in place.

 

Who we share your information with

We only share personal information where there is a valid reason and the disclosure is necessary and proportionate.

We may share information with credit reference, identity verification, fraud prevention and sanctions screening providers, banks and payment processors, core banking and account administration providers, app, website, communication, IT, hosting and cybersecurity providers, open banking providers, governance, risk and compliance providers, marketing and survey providers, debt recovery agencies, tracing services, solicitors, courts, insolvency practitioners, auditors, accountants, insurers and professional advisers.

Where you use a payroll product, we may share the limited information needed with your employer or payroll provider to set up, amend, stop or reconcile deductions. We don’t tell your employer about your wider financial circumstances, unless you specifically consent to this.

We may share information with government departments, benefit payment services, local authorities, regulators, law enforcement agencies, tax authorities and the Financial Ombudsman Service where this is required or permitted by law or is needed to comply with a legitimate activity.

We may also share information as part of a merger, transfer, restructuring or other change to our business, subject to appropriate safeguards.

Some organisations, such as banks, regulators and credit reference agencies, use information under their own privacy notices. Other providers process information only on our instructions.

We don’t sell your personal information and we don’t share it with other organisations for their own direct marketing.

Our suppliers may change from time to time. We require providers processing information on our behalf to comply with the requirements set out in UK data protection legislation, keep your data secure and only use it for authorised purposes.

 

Statutory records and registers

Credit unions are required to maintain certain statutory records and registers.

Information in these records may need to be kept permanently, or for extended periods of time.

We only disclose information the law requires or permits and apply the safeguards available to us.

 

Sending information outside the UK

Our main systems and service providers are based in the UK. However, some providers or their approved subcontractors may access or process information from other countries.

Where personal information is transferred outside the UK, we make sure there is a lawful transfer mechanism in place. This may include UK adequacy regulations, the UK International Data Transfer Agreement, appropriate safeguards, or an exemption permitted by law.

Where required, we assess the protection available in the destination country and put additional technical, contractual or organisational controls in place to control the risk.

 

Marketing choices

You’re in control of whether you receive direct marketing from us.

You can unsubscribe using the link in a marketing email, change your preferences in our app or by logging into your account via a web browser, or by contacting us.

We will keep a record of your marketing preferences, so that we can comply you’re your any opt outs.

Opting out of marketing won’t stop general messages such as account, application, security, regulatory or service messages. Nor will it prevent you from seeing non-direct marketing that isn’t targeted to you personally, for example a generic banner ad promoting a product on our website.

 

How long we keep your information

We keep personal information only for as long as we reasonably need it. The exact period depends on the type of information, why we hold it and any legal, regulatory or reporting requirements.

For example, we will normally keep information about your account and transactions for seven years after your relationship with us ends. Some records, including certain membership records, may need to be kept for longer or permanently.

Marketing information is kept while you receive marketing and for as long as needed afterwards to evidence your preferences and maintain an opt-out record.

Some statutory credit union registers need to be kept permanently.

We may keep information beyond our usual retention periods where we reasonably consider this necessary for our legitimate interests, provided those interests are not outweighed by your rights and freedoms. This may include dealing with an ongoing complaint or dispute, investigating or preventing fraud, responding to a court or regulator, or establishing, exercising or defending legal rights. We may also keep information for longer where we are required to do so by law or regulation.

When we no longer need information, we securely delete it, anonymise it or place it beyond operational use.

 

Junior Saver accounts

Where an account holder is a child, we collect information about both the child and their parent, guardian or authorised adult.

We use this information to confirm identity and eligibility, open and manage the account, process transactions, communicate about the account, protect it from fraud and meet our legal obligations.

We aim to explain how information is used in a way that is suitable for the child’s age. Where appropriate, communications may be directed to the authorised adult connected to their account.

We do not use children’s personal information to target advertising at them or make solely automated decisions that have a legal or similarly significant effect on them.

 

Keeping your information safe

We use appropriate technical and organisational measures to protect personal information.

These include access controls, authentication, encryption, system monitoring, security testing, staff training, confidentiality requirements, supplier checks, contractual controls, backup arrangements and incident management procedures.

Access is limited to people who need the information for their work.

No system can be guaranteed to be completely secure. You should keep your passwords, authentication codes and devices safe and tell us immediately if you think your account or information has been compromised.

 

Your rights

Data protection law gives you several rights. They don’t apply in every situation and there may be legal exemptions, but we’ll explain this if it affects a request.

 

To be informed: You have the right to know how and why we use your personal information. That is what this privacy notice is for. We explain what information we collect, where it comes from, how we use it, who we share it with, how long we keep it and the rights you have.

 

Access: You can ask whether we hold personal data about you and request a copy. This is commonly known as a Subject Access Request (SAR).

 

Rectification: You can ask us to correct inaccurate information or complete information that is incomplete.

 

Erasure: You can ask us to delete information where there is no longer a lawful reason to keep it. This right doesn’t override legal, regulatory or record-keeping requirements.

 

Restriction: You can ask us to limit how we use your information in certain circumstances.

 

Portability: You may be able to receive certain information you provided in a structured, commonly used and machine-readable format, or ask us to transfer it to another organisation where technically possible.

 

Objection: You can object where we rely on legitimate interests. We’ll stop unless we have compelling legitimate grounds to continue or need the information for legal claims.

You have an absolute right to object to direct marketing. If you ask us to stop, we will stop using your information for marketing and update your marketing preferences across our systems.

 

Withdraw consent: Where we rely on your consent, you can withdraw it at any time. This won’t affect anything we did before you withdrew it.

 

Automated decisions: Where the additional safeguards apply, you can make representations, provide more information, ask for a human review and challenge a significant automated decision. This applies to a decision that is solely automated, meaning there is no meaningful human involvement; and produces a legal effect or a similarly significant effect on you.

 

We may need to confirm your identity before responding. You won’t normally need to pay a fee, although we may charge a reasonable fee or refuse to act where a request is manifestly unfounded or excessive, as permitted by law.

 

Rights and requests

You have the right to rectification, erasure, to restrict processing, data portability, to object and rights in relation to automated decision making or profiling. CLEVR Money will carefully consider any requests under these rights and requests can be submitted to the Data Protection Lead who will consult with the Data Protection Officer.

‘Subject access’ requests should be directed to our Data Protection Lead.

The contact for our Data Protection Lead are as follows:

Email governance@clevr.money or write to:

Data Protection Lead (Chief Operating Officer)
CLEVR Money
13 Birley Street
Blackpool
FY1 1EG

We’ll respond to a subject access request without undue delay and normally within one month. If we need more time because your request is complex or you have made several requests, we may extend this by up to two further months. We’ll let you know within the first month and explain why.

 

Complaints

If you are unhappy with the way that we are handling your personal data or information, or with our response to a ‘Subject Access Request’, you can submit a complaint to the Data Protection Officer. The Data Protection Officer will carefully consider each complaint on a case-by-case basis and submit a response without undue delay.

We’ll acknowledge a data protection complaint within 30 days, investigate it appropriately, keep you informed where the investigation is still ongoing and tell you the outcome without undue delay.

The contact details for our designated Data Protection Officer are:

Email: dataprotectionofficer@blackpool.gov.uk or write to:

Data Protection Officer
Blackpool Council
PO Box 4
Blackpool
FY1 1NA

 

We ask that you submit your complaint to us in the first instance, however you do have the right to complain directly to the Information Commissioner’s Office:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113

You can also make a complaint through the Information Commissioner’s Office website.

 

Cookies

Like most websites, we use cookies and similar technologies to help our website function, improve user experience, and understand how our services are used.

 

Some cookies are essential for the operation of our website and do not require your consent. Where we use cookies or similar technologies that require consent under applicable privacy legislation, we will ask for your consent and provide you with the ability to manage or change your preferences at any time.

 

Further information about the cookies we use and how to manage them can be found in our Cookie Policy.

 

Other websites and services

Our website and app may link to websites and services operated by other organisations. Their privacy notices apply when you use those services, so you should read them before providing personal information.

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Changes to this notice

We’ll update this notice when necessary, which is usually when our products, services, systems, suppliers or legal obligations change.

The latest version will always be available on our website. If we make a significant change, we may also tell you through our app, by email or through another appropriate channel.