Citrus Loans is a trading style of Aspire Money Limited and we are committed to safeguarding and respecting the privacy of our customers.
This policy applies where we are acting as a data controller with respect to the personal data of our customers; in other words, where we determine the purposes and means of the processing of that personal data.
This policy sets out the basis on which any personal information we collect from you, or that you provide to us through our website or via our contact centre, will be processed by us.
Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.
By visiting this website or providing your personal information to one of our contact centre consultants, you are accepting and consenting to the practices described in this policy. Please note that this includes consenting to the processing of any sensitive personal information you provide.
Date Published: 18/05/2018
I need to know the details of the Data Controller
Why we collect your personal data and what is our lawful basis for processing
Do we require your consent for processing of personal data?
How we obtain your personal Information?
Categories of data we collect from you
Will we conduct a credit check?
Do we conduct Fraud Prevention and Detection?
Who we share your information with
Will your data be transferred out of the EU, and if so will it be safe?
How long we keep hold of your information?
Will you be subject to automated decision making?
What rights do you have in respect of the personal data we hold about you?
What happens if you don't provide your personal details?
I didn't give you my personal details, so what is its source and what types of personal data are you processing?
1. I need to know the details of the Data Controller
1.1 This website is owned and operated by Citrus Loans which is a trading style of Aspire Money Limited
1.2 We are registered in England under FCA registration number 681346, and our registered office is at Unit 1, Castle Court 2, Castlegate Way, Dudley, West Midlands DY1 4RH.
1.3 Should you wish to confirm our registration details please click here here.
1.4 We are also registered with the Information Commissioners Office; under registration number Z1262766. Should you wish to confirm our registration details please click here
1.5 Our principal place of business is at 24 Flanders Drive, Mount Edgecombe, Durban, KwaZulu Natal, South Africa, 4300
1.6 You can contact us:
by post, to the postal address given above
using our website contact form here.
by telephone on 020 3915 9996.
by email using firstname.lastname@example.org.
2. Why we collect your personal data and what is our lawful basis for processing
2.1 We are a loan broker, and in order to find you the most suitable loan option, we will need to collect and process certain categories of your personal data. We will not collect or process this information without first gaining your consent to do so.
2.2 We will process the information contained in any enquiry you submit to us regarding our services. This information will be processed for the purposes of offeringour services to you which in this case will be finding you the most suitable lender to assist you with the loan you are searching for.
2.3 We and our lenders will retain and use the personal data you provide us for statistical analysis and analytics regardless of whether or not you take up a loan with our lender's. Where we do this, we take strict measures to ensure that individuals cannot be identified.
2.4 Our legal basis for this processing is your consent to process your enquiry or application
3. Do we require your consent for processing of personal data?
You will need to provide us with consent to
Process your personal data once you have completed your loan application
Pass your information over to our lending panel, to assist you in finding a suitable loan option
Pass you data over to Credit Reference agencies who may undertake credit searches
Use automated decision making to process your details and provide you with an option/s with regards to your loan enquiry
You have the right to withdraw any consent you have given us, regarding the processing of your information.
In order to do this, please use any of the preferred methods of communication below
by post, to the postal address given above
using our website contact form here.
by telephone on 020 3915 9996.
by email using email@example.com.
4. How we obtain your personal Information?
There are many different ways in which we could obtain your data
From our website, if you complete our online application form
If you telephone us to make a loan application
Certain Lenders and Financial Brokers may pass your information over to us, should they be unable to assist you with a loan. Please note that if this is the case we will provide you with the identity of these individual firms
5. Categories of data we collect from you
The categories of data that we collect are as follows:
Your Consent to:
Sending out our Full Disclosure document
Collecting and recording details around any vulnerability you may have Note that the sensitive data we collect regarding information on your vulnerability is collected to ensure that we are able to assist you in a manner that does not affect your understanding of our loan application process. To ensure that you are fully aware and are able to make sound financial decisions regarding your application. We do not share this information with any or our affiliate companies
Partner Details (should you request to complete a joint application)
Partner Employment Details (should you request to complete a joint application)
Mortgage Details or Tenancy Details
Other Income & Expenditure you might incur
Your Financial Status i.e. Bankruptcy, Defaults & Missed Payments, Count Court Judgements, Individual Voluntary Arrangement & Debt Management Plan
6. Will we conduct a credit check?
In order to process your application, we will perform credit and identity checks on you with one or more Credit Reference Agencies ("CRAs").
To do this, we will supply your personal information to CRAs and they will give us information about you. The information we will supply to the Credit Reference Agency will include information from your credit application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.
The information which we and other organisations provide to the credit reference and fraud prevention agencies may be supplied by credit reference agencies to other organisations and used by them to perform similar checks
If you are making a joint application or tell us that you have a spouse or financial partner, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. CRAs will also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.
We will use this information to help our lenders:
Assess your credit worthiness and whether you can afford to take the product;
Verify the accuracy of the data you have provided to us;
Prevent criminal activity, detect fraud and money laundering;
Manage your account(s);
Ensure any offers provided to you are appropriate to your circumstances.
When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders whether or not the application proceeds.
When you complete an application our lenders will do soft searches which do not leave a footprint on your file, however, once you take up an offer with the lender's they may conduct a hard search which will be recorded.
We have included definitions to Soft and Hard searches below, to help you understand how these work
What is a soft credit search?
Not every instance of your credit report being checked by a lender will result in a visible 'footprint' being left on your report. There is such a thing as a 'soft credit search' or a 'soft credit check', which is recorded in your credit history, but is not visible to other lenders. This includes things such as identity checks and quotations, where a company confirms the details you have provided are correct when offering you a quote.
What is a Hard Credit Search?
Hard searches are initiated when you make a formal application to a credit product, like a credit card, loan, or mortgage. Hard searches provide the lender with full access to your credit report so they can make an informed decision regarding your application. Each formal credit application you make will initiate a hard search that will show on your credit report for a year. Too many of these marks in a short period of time can reduce your credit score and scare off potential lenders, as too many credit applications in a short period of time may be a sign you are struggling financially.
The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail which is accessible from each of the three CRAs.
The credit reference agencies used by us and our lenders are Experian, Call Credit and Equifax.
Clicking on any of these three links will also take you to the Credit Reference Agency Information (CRAIN) document:
7. Do we conduct Fraud Prevention and Detection?
We may make searches of records held at fraud prevention agencies. If you give us false or inaccurate information and we confirm fraud, we will record this and may pass this information to fraud prevention agencies and other organisations to prevent fraud and money laundering. Law enforcement agencies may access and use this information.
We share personal data for crime and fraud prevention and the apprehension and prosecution of offenders.
We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.
The information which we, other organisations and fraud prevention agencies provide to the credit reference and fraud prevention agencies about you and your financial associates may be supplied by the credit reference and fraud prevention agencies to other organisations and used by us and them for example to:
Prevent fraud and money laundering,
Verify your identity if you or your financial associate applies for other facilities including all types of insurance applications and claims,
Assist other organisations to make decisions on credit and credit related services or other facilities,
Trace your whereabouts and recover debts that you owe,
Managing credit and credit related accounts and other facilities and
Undertake statistical analysis and system testing.
Checking details on applications for credit and credit related accounts or other facilities.
Checking details of job applicants and employees.
8. Who we share your information with
a) Our Lenders
Lenders we work in association with:
Please see below a list of lenders or companies that we may share your information with
1st Stop Personal Loans
1st Stop Secured Loans
Guarantor My Loans
One Plus One
Opal Loans Secured
Pounds to Pocket
b) Service Providers
We may provide your personal information to anyone who hosts or maintains data centres, service platforms and other infrastructure and systems on behalf of us, where your personal information is processed and/or stored;
Except as described above, we will not disclose your personal information to Third Parties, without your consent.
Please be reassured that we will not release your information to third parties beyond our firm and its trading styles for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.
You may be assured that we and any company associated with us will treat all personal data and sensitive personal data as confidential and will not process it other than for reasons you have provided consent for.
Measures will also be taken to safeguard against unauthorised or unlawful processing and accidental loss or destruction or damage to data.
We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or re-organisation.
We may also disclose personal information about you to the extent required by Law, Court Order, by Government order or decree.
However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.
9. Will your data be transferred out of the EU, and if so will it be safe?
As part of the services offered to you through this website, the information which you provide to us may be transferred to countries outside the European Union ("EU"), that being our principle place of business which is our call center based in South Africa and lenders based in the USA.
By submitting your personal data, you're agreeing to this transfer, storing or processing.
If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.
10. How long we keep hold of your information?
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes
Personal data categories will be retained for a minimum period of 12 months following the date of your enquiry, and for a maximum period of6 years following the date of your enquiry.
11. Will you be subject to automated decision making?
We may carry out automated decision making once your loan application is completed. This is done in an effort to ensure that we are able to provide you with the suitable loan options you might qualify quickly and efficiently.
12. What rights do you have in respect of the personal data we hold about you?
We have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under data protection law are:
12.1 the right to access
12.2 the right to rectification
12.3 the right to erasure
12.4 the right to restrict processing
12.5 the right to data portability
12.6 the right to withdraw consent
12.7 the right to complain to a supervisory authority
12.1 The right to access
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
If your information has been passed over to our lender/s you will need to contact them requesting the information they will hold about you.
12.2 The right to rectification
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
If your information has been passed over to our lender/s you will need to contact them requesting them to correct any inaccurate information they might hold about you.
12.3 The right to erasure
In some circumstances you have the right to the erasure of your personal data without undue delay.
Those circumstances include:
the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
you withdraw consent to consent-based processing;
you object to the processing under certain rules of applicable data protection law;
the processing is for direct marketing purposes;
the personal data have been unlawfully processed
However, there are exclusions of the right to erasure.
The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims
If your information has been passed over to our lender/s you will need to contact them requesting to exercise your right to erasure, regarding the information they hold about you.
12.4 The right to restrict processing
In some circumstances you have the right to restrict the processing of your personal data.
Those circumstances are:
you contest the accuracy of the personal data;
processing is unlawful but you oppose erasure;
we no longer need the personal data for the purposes of our processing, but we require personal data for the establishment, exercise or defence of legal claims;
you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data.
However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
If your information has been passed over to our lender/s you will need to contact them requesting to exercise your right to restrict processing, regarding the information they hold about you.
12.5 The right to data portability
To the extent that the legal basis for our processing of your personal data isconsent; and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
If your information has been passed over to our lender/s you will need to contact them requesting to exercise your right to data portability, regarding the information they hold about you.
12.6 The right to withdraw consent
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data by emailing us at: firstname.lastname@example.org, or write to us at: Unit 1, Castle Court 2, Castlegate Way, Dudley, West Midlands DY1 4RH. Alternatively, you can telephone 02039159996
If your information has been passed over to our lender/s you will need to contact them requesting to exercise your right to withdraw consent, regarding the information they hold about you and any other consent you may have provided to them over the use of your information.
12.7 The right to complain to a supervisory authority
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection, the Information Commissioners office. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement
You may also lodge a complaint directly with us by emailing us at: email@example.com, or write to us at: Unit 1, Castle Court 2, Castlegate Way, Dudley, West Midlands DY1 4RH. Alternatively, you can telephone 02039159996
13. What happens if you don't provide your personal details?
In order to process your loan enquiry, we will require you to complete our online loan application, or telephone our contact centre and complete an application with one of our consultants. We require this information to assist you in finding you a suitable loan option. We will not collect or process your information unless you have provided us with consent to do so.
To find out what personal data we require from you please click here
14. I didn't give you my personal details, so what is its source and what types of personal data are you processing?
We may receive information about you if you use any of our other websites i.e. Citrus Loans and Opal Loans which are Trading Styles of Aspire Money Limited.
We also work closely with third parties for example other Credit Brokers, Business partners and Lenders who you may have contacted to assist you with your loan enquiry. These third-party companies may have not been able to assist you with your enquiry and may have noticed that we could possibly assist you, in this case they would have passed your information over to us, ensuring that your consent is gained.
15. About cookies
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Below is a table of information which lists all cookies used on our website.
_utma (Google Analytics)
A Google Analytics cookie, which keeps track of the number of times, a visitor has been to the site, when their first visit was, and when their last visit occurred.
_utmb (Google Analytics)
A Google Analytics cookie, which creates a timestamp of the exact moment when a visitor enters a site.
_utmc (Google Analytics)
A Google Analytics cookie, which creates a timestamp of the exact moment when a visitor leaves the site.
_utmv (Google Analytics)
Used for reporting in Google Analytics classifying the visitor.
_utmz (Google Analytics)
A Google Analytics cookie which tracks where the visitor came from, what search engine was used, what link was clicked on, what keywords used, and where in the world the site was accessed from.
We may update this policy from time to time by publishing a new version on our website.
You should check this page occasionally to ensure you are happy with any changes to this policy.