Updated July 18,2018.

How we use your personal information

Your information will be held by Bank of Scotland plc, which trades as Zenithunion Banking Group. This privacy notice is to let you know how companies within the Group promise to look after your personal information. This includes what you tell us about yourself, what we learn by having you as a customer, and the choices you give us about what marketing you want us to send you. This notice also tells you about your privacy rights and how the law protects you.

Our Privacy Promise

We promise:

To keep your data safe and private.

Not to sell your data.

To give you ways to manage and review your marketing choices at any time.

Personal information and the law

This section tells you who we are, what your personal information is, and how we get it. It explains how the law protects you by controlling what is allowed to happen to it.

1. Who we are

2. How the law protects you

3. Groups of personal information

4. Where we collect personal information from

5. How long we keep your personal information

6. If you choose not to give personal information

7. Cookies

The control you have

This section covers how to complain or withdraw your consent. It also tells you how you can get a copy of your personal information, or ask for it to be changed or removed.

8. How to complain

9. How to withdraw your consent

10. Letting us know if your personal information is incorrect

11. How to get a copy of your personal information

12. What if you want us to stop using your personal information?

How personal information is used

This tells you who we share personal information with. It explains what it’s used for in marketing, to provide credit and to combat fraud – and how this can affect you.

13. Who we share your personal information with

14. How we work out what marketing you receive

15. How we use your information to make automated decisions

16. Credit Reference Agencies (CRAs)

17. Fraud prevention agencies

18. Sending data outside of the EEA

More information about your identity

Proving your identity

How we remember your username

Identity theft

Personal information and the law

Who we are

This section gives you the legal name of the company who holds your personal information – known as the ‘legal entity’ – and tells you how you can get in touch with us.

Zenithunion Banking Group is made up of a mix of companies, set up on different legal entities. We’ll let you know which you have a relationship with, when you take out a product or service with us.

Contacting us about data privacy

Please use these details to contact us about any of the topics set out in this Privacy notice.

If you have any questions, or want more details about how we use your personal information, you can ask us using our secure online contact form.

Lines are open 24 hours a day, 7 days a week.

Calls may be monitored or recorded.

If you have a hearing or speech impairment you can also call us using the Next Generation Text (NGT) service. Simply dial 18001 and then the telephone number.

If you’re Deaf and a BSL user, you can talk to us live through a BSL interpreter online using our BSL SignVideo service.

These are our main contact details. Some sections of this notice have special contact details that you can use instead.

If you are not satisfied with our response, you can contact our Group Data Protection Officer.

How the law protects you

This section sets out the legal reasons we rely on, for each of the ways we may use your personal information.

As well as our Privacy Promise, your privacy is protected by law. This section explains how that works.

Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside Zenithunion Banking Group. The law says we must have one or more of these reasons:

To fulfil a contract we have with you, or

When it is our legal duty, or

When it is in our legitimate interest, or

When you consent to it.

When we have a business or commercial reason of our own to use your information, this is called a ‘legitimate interest’. We will tell you what that is, if we are going to rely on it as the reason for using your data. Even then, it must not unfairly go against your interests.

The law and other regulations treat some types of sensitive personal information as special. This includes information about racial or ethnic origin, sexual orientation, religious beliefs, trade union membership, health data, and criminal records. We will not collect or use these types of data without your consent unless the law allows us to do so. If we do, it will only be when it is necessary:

For reasons of substantial public interest, or

To establish, exercise or defend legal cliams.

Here is a list of all the ways that we may use your personal information, and which of the reasons we rely on to do so. This is also where we tell you what our legitimate interests are.

Where we collect personal information from

This section lists all the places where we get data that counts as part of your personal information.

We may collect personal information about you (or your business) from other Lloyds Banking Group companies and any of these sources:

Data you give to us:

When you apply for our products and services

When you talk to us on the phone or in branch, including recorded calls and notes we make

When you use our websites, mobile device apps, web chat or SignVideo services

In emails and letters

In insurance claims or other documents

In financial reviews and interviews

In customer surveys

If you take part in our competitions or promotions

Data we collect when you use our services.

This covers two things: details about how and where you access our services, and account activity that is shown on your statement.

Payment and transaction data.

This includes the amount, frequency, type, location, origin and recipients

Profile and usage data.

This includes the security details you create and use to connect to our services. It also includes your settings and marketing choices. We also gather data from the devices you use (such as computers and mobile phones) to connect to our internet, mobile and telephone banking services.

We also use cookies and other internet tracking software to collect data while you are using our websites or mobile apps. You can find out more about this in our Cookies policy.

Data from outside organisations:

Companies that introduce you to us (such as a store or car dealership offering finance deals through us)

Financial advisers

Credit Card providers like Visa and Mastercard

Credit reference agencies such as Callcredit, Equifax and Experian

Insurers

Retailers

Comparison websites

Social networks (for instance, when you click on one of our Facebook or Google ads)

Fraud prevention agencies

Other financial services companies (to help prevent, detect and prosecute unlawful acts and fraudulent behaviour)

Employers (for instance, to get a reference if you apply for a mortgage)

Payroll service providers

Land agents (such as firms who do property valuations for mortgages)

Public information sources such as the Electoral Register or  Companies House

Loyalty schemes like Avios or Everday Offers

Agents, suppliers, sub-contractors and advisers

These can be types of firms we use to help us run accounts and services. They can also be specialist companies who advise us on ways to develop and improve our business.

Market researchers (who combine data from many sources to produce market trend reports and advice)

Medical professionals*

Government and law enforcement agencies

* For some insurance products, we may ask your GP or other medical practitioner to send us a report. We will only do this if we get your consent first.

How long we keep your personal information

This section explains how long we may keep your information for and why

We will keep your personal information for as long as you are a customer of Lloyds Banking Group.

We may keep your data for up to 10 years after you stop being  a customer. The reasons we may do this are:

To respond to a question or complaint, or to show whether we gave you fair treatment

To study customer data as part of our own internal research

To obey rules that apply to us about keeping records

We may also keep your data for longer than 10 years if we cannot delete it for legal, regulatory or technical reasons. As an example, we have to hold pension transfer information indefinitely; and in cases of subsidence* we will keep insurance claims data for up to 15 years after you stop being a customer.

We will only use your personal information for those purposes and will make sure that your privacy is protected.

* Subsidence is when a building becomes unsafe or damaged by ground sinking around it.

If you choose not to give personal information

You can choose not to give us personal information. In this section we explain the effects this may have.

We may need to collect personal information by law, or to enter into or fulfil a contract we have with you.

If you choose not to give us this personal information, it may delay or prevent us from fulfilling our contract with you, or doing what we must do by law. It may also mean that we cannot run your accounts or policies. It could mean that we cancel a product or service you have with us.

We sometimes ask for information that is useful, but not required by law or a contract. We will make this clear when we ask for it. You do not have to give us these extra details and it won’t affect the products or services you have with us.

Cookies

This section contains a link to our Cookies Policy

Cookies are small computer files that get sent down to your PC, tablet or mobile phone by websites when you visit them. They stay on your device and get sent back to the website they came from, when you go there again. Cookies store information about your visits to that website, such as your choices and other details. Some of this data does not contain personal details about you or your business, but it is still protected by this Privacy notice.

To find out more about how we use cookies, please see our Cookies Policy.

The control you have

How to complain

This section gives details of how to contact us to make a complaint about data privacy. It also shows you where you can get in touch with the government regulator.

Please let us know if you are unhappy with how we have used your personal information. You can contact us using our secure online contact form.

You also have the right to complain to the regulator, and to lodge an appeal if you are not happy with the outcome of a complaint.

In the UK this is the Information Commissioner’s Office. Find out on their website how to report a concern.

In Jersey, please contact the Office of the Information Commissioner

In Guernsey, please contact the Office of the Data Protection Commissioner

In Isle of Man, please contact the Information Commissioner

How to withdraw your consent

This section explains what to do if you no longer want us to hold or use your personal information.

You can withdraw your consent at any time. Please contact us using our secure online contact form if you want to do so.

This will only affect the way we use information when our reason for doing so is that we have your consent. See the section ‘Your Rights’ about more generally restricting use of your information.

If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.

Letting us know if your personal information is incorrect

Here you can find out how to contact us if you think the information we hold for you is wrong, incomplete or out of date.

You have the right to question any information we have about you that you think is incorrect. We’ll take reasonable steps to check this for you and correct it.

If you want to do this, please contact us using our secure online contact form. 24 hours a day, 7 days a week.

Calls may be monitored or recorded.

If you have a hearing or speech impairment you can also call us using the Next Generation Text (NGT) service. Simply dial 18001 and then the telephone number.

If you’re Deaf and a BSL user, you can talk to us live through a BSL interpreter online using our BSL SignVideo service.

How to get a copy of your personal information

This section tells you where to write to us to get a copy of your personal information, and how to ask for a digital file you can use yourself or share easily with others. You can do this online or by writing to us.

Your rights

What if you want us to stop using your personal information? This section explains about your right to object and other data privacy rights you have – as well as how to contact us about them.

You can object to us keeping or using your personal information. This is known as the ‘right to object’.

You can also ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to erasure’ or the ‘right to be forgotten’.

There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.

We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights.

You can ask us to restrict the use of your personal information if:

It is not accurate

It has been used unlawfully but you don’t want us to delete it

It is not relevant any more, but you want us to keep it for use in legal claims

You have already asked us to stop using your data but you are waiting for us to tell you if we are allowed to keep on using it

If we do restrict your information in this way, we will not use or share it in other ways while it is restricted.