Your Privacy is Our Priority

This privacy notice sets out how we collect, use and manage your personal data. Where we refer to “personal data” in this privacy notice, this means data which relates to you and which personally identifies you either directly or indirectly.

Data Controllers and Data Protection Officer

A data controller is an organisation that collects, uses and manages personal data and has responsibility for how the personal data is collected, used and managed.

A data protection officer is the person in an organisation who has responsibility for monitoring compliance with data protection law and for ensuring that personal data is protected within an organisation.

TTBRC LTD provides your goods and is the data controller of personal data that you provide when you order goods. TTBRC LTD is registered in England, number: 13247200 . Registered Office: 59 Willow Walk, London, N21 1NG. TTBRC LTD’s websites are www.ttb-c.com and www.dividepay.co.uk

TTBRC LTD provides credit, subject to status, and arranges other financial services products and is the data controller of personal data you provide when you request a credit account or other financial services products. TTBRC LTD is registered in England, number: 13247200.

In the context of this privacy notice, when we use the term 'we' it means TTBRC LTD.

How We Use Your Personal Data

We collect, use and manage your personal data to provide goods and services to you and to enter into and administer any credit accounts or financial services products you may have with us.

We will use your personal data in the following ways:

• To provide goods and services and to manage your retail account including administering payments, returns and responding to queries.

• To assess whether to offer you a credit facility and for ongoing administration of any credit facility. This includes accessing and sharing information with the Credit Reference Agencies.

• To administer any financial services products that you have.

• To administer any prize draw or competition you may enter.

• To analyse your shopping preferences or how you interact with or use our websites.

• For research and statistical purposes.

• For marketing purposes including to send you special offers or discounts and to tell you about products and services from us or third parties. This may also include levels of profiling to ensure we market to you about relevant products and services. You control your preferences in respect of how your personal data is used for marketing and you can change these preferences when you log in to My Account.

• To record and monitor outbound and inbound telephone conversations with you to ensure consistent service levels, to prevent or detect fraud, to resolve queries and complaints and for performance management and training purposes.

We will collect personal data directly from you when you purchase goods or services, apply for a credit account or other financial services products, or change any of your details (such as your name or address) via My Account. We require you to provide personal data in order to assess whether to enter into a contract with you or to perform our contract with you and if you do not provide the personal data we request, we will be unable to enter into or fulfil this contract. We may also collect personal data through cookies.

We obtain data from third party sources such as credit reference agencies, fraud prevention agencies and publicly available information relating to you on the internet (for example on social media websites).

We may also obtain personal data from third party companies for the purposes of sending marketing communications to you. Such marketing communication may be sent by ourselves or by the third parties. These third parties must check you have given your permission for such contacts to take place.

Why We Need Your Personal Data

We need to process your personal data for a number of different reasons and these are our legal bases for processing. We also need to keep your personal data for as long as is necessary for us to operate our business and to comply with legal and regulatory obligations.

We rely on one or more of the following legal bases for processing personal data:

• To perform our contract with you or to enter into a contract with you

  We need to process your personal data to fulfil our contract with you or to assess whether to enter into a contract with you, whether this is in selling and delivering goods and services to you or providing credit facilities or other financial services products to you.

• To fulfil our legitimate interests or the legitimate interests of a third party

  When we process personal data to fulfil our legitimate interests we will use it in a way in which you would reasonably expect and which will have a minimal privacy impact. When we or third parties are relying on legitimate interests to process your data we will balance our interests against your interests and the privacy impact of the processing on you and we will process your personal data responsibly.

  Examples of our legitimate interests are: direct marketing, fraud prevention, preventing and investigating crime, assessing affordability and credit worthiness, IT security and development by us and third parties of new products and services.

• To comply with legal obligations to which our business is subject.

  We have to comply with relevant law and regulation in order to provide retail and financial services products and we will need to process your personal data in order to comply with these legal obligations.

• Consent

  If we are relying on your consent as our legal basis to process your personal data, you have the right to withdraw consent at any time.

We will keep your personal data for the purposes set out in this privacy notice and only for as long as any legal basis continues to apply. Below is a non exhaustive list of some of the reasons we need to retain your personal data:

• Compliance with the requirements of the Financial Conduct Authority

• Compliance with Anti Money Laundering Regulations

• Reporting obligations to the Credit Reference Agencies

• Ensuring we have relevant information in the event of any queries or complaints

• Being able to identify if you have purchased a product which is subject to a product recall

• Being able to service any product or service guarantee you have purchased

• To assist with the establishment, exercise or defence of legal claims

The length of time we need to keep the personal data will vary depending on the nature of the personal data and the reason we are obliged to hold it. We will apply appropriate risk based measures to protect your personal data which may include pseudonymising or anonymising the personal data. If personal data is pseudonymised, this means it is de-identified so you are no longer identifiable, but we can re-identify you if we have a requirement to do so. If personal data is anonymised, it is de-identified, but can never be re-identified in the future.

Who We Transfer Personal Data To

Transferring personal data to other organisations needs to take place with appropriate safeguards and you can be assured that we will only share the personal data that is needed for these organisations to be able to provide the right service or support us in doing so.

We may transfer your personal data to the following third parties:

• Other companies within TTBRC LTD of companies – including for credit assessment purposes, for fraud prevention purposes or for the provision of other products and services.

• Customer service providers – our partners who work with us to administer your account and provide you with any help you may need.

• Telephony providers – our partners who provide telephone services and functionality.

• Delivery companies – our couriers, parcel firms and mail firms who deliver your goods or services and manage any returns on our behalf.

• Repair companies – our partners who provide repair services for products.

• Distributors and manufacturers of goods – our partners who fulfil orders and deliver products to you and manage any returns on our behalf.

• Product service providers – our partners who provide retail or financial products and services including credit facilities, payment facilities, insurance or extended warranties.

• Research service providers – our partners who work with us to provide research and data analysis services.

• Marketing service providers – our partners who work with us to send you information about products, services and special offers that we or they believe are of interest to you.

• Data pool facilitators – we may share and pool information (on an anonymous basis or otherwise) with other third party retailers or financial service providers. This may help up to improve our products and quality of service to all customers.

• Debt collectors, tracing agencies, debt purchasers or organisations providing debt support – our partners who help us to recover debts, who purchase debts or who offer debt advice and support.

• Regulators and other governmental agencies or law enforcement agencies.

• Organisations who may be interested in purchasing our business or organisations who we may be interested in purchasing - we may sell parts of our business or acquire other businesses and your personal data may be shared with such third parties as part of this process.

We will only transfer your personal data to third parties who adhere to appropriate data security standards and controls. This may include transferring your personal data to third parties who become joint controllers of the data, including some organisations within the following categories:

• Credit reference agencies and credit providers

• Distributors of goods

• Marketing service providers, such as Google or Facebook

• Regulators and other governmental agencies or law enforcement agencies

• External auditors

• Debt collectors, tracing agencies, debt purchasers or organisations providing debt support

Facebook

If you have agreed to receive marketing communications from Divide Pay, your personal data including purchasing and browsing activity, may be shared with Facebook so that they can serve BRAND adverts to you when you are using Facebook platforms and apps, including Facebook and Instagram. For certain data processing activities relating to this marketing, Facebook will act as joint controller.

Further information on how Facebook Ireland processes Personal Data, including the legal basis Facebook Ireland relies on and the ways to exercise Data Subject rights against Facebook Ireland, can be found in Facebook Ireland's Data Policy at https://www.facebook.com/about/privacy.

TTBRC LTD and Facebook have entered into an agreement incorporating a ‘Controller Addendum’ to determine each party’s respective responsibilities for compliance with the obligations under the GDPR with regard to the joint processing.

We have agreed that TTBRC LTD is responsible for providing the above information and agreed that between the Parties, Facebook Ireland is responsible for enabling Data Subjects' rights under Articles 15-20 of the GDPR with regard to the Personal Data stored by Facebook Ireland after the Joint Processing.

From time to time we may need to transfer your personal data to other countries. Where this is the case, we will ensure that the transfer is subject to appropriate safeguards to protect your personal data and complies with applicable law which may include having standard contractual clauses in place with the third party. For further information on how data can be transferred to other countries, please find enclosed a link to the European Commission website: https://ec.europa.eu/info/law/law-topic/data-protection_en

World Pay

Worldpay is a merchant services and payment processing provider offering a payment gateway for online transactions. Divide Pay has joint controller status with Worldpay and share personal transaction data. For further information on how Worldpay process personal transaction data please see Worldpay’s Privacy Statement which can be found on Worldpay’s corporate website.

Your Rights

You have certain rights in respect of your personal data and we have processes to enable you to exercise these rights.

Right to Rectification

If you believe that we hold inaccurate personal data about you, then you can update this information directly by logging in to My Account and updating the relevant details.

Alternatively, you can request that we carry out a review and rectify any incomplete or inaccurate personal data we hold about you by calling our Customer Services Team. Depending on the type of personal data you believe is inaccurate, we may ask you for further proof to ensure that the personal data is being corrected properly. If we are satisfied that the personal data is inaccurate we will make the necessary changes.

Right to Erasure

You have a right to ask for your personal data to be erased. However, we are not required to erase your data where we need your personal data to comply with a legal obligation or for the establishment, exercise or defence of legal claims. Therefore we cannot comply with an erasure request where you have a retail shopping account, owe money on a credit facility or have otherwise bought products and services for which we must keep records. In addition, if you opt out of marketing communications or have previously opted out of marketing communications, we have to keep a record or such opt out to ensure that we don’t contact you in the future.

Right to Restriction

You have a right to request that processing of personal data is restricted in certain circumstances. Where we restrict your data, we are permitted to store your data but we cannot process in any other way apart from for the establishment, exercise or defence of legal claims or with your consent.

Right to Object

Where we are relying on legitimate interests as a legal basis to process your data, you have a right to object to such processing on grounds relating to your particular situation.

If you object to our use of your personal data for direct marketing purposes, we will opt you out of direct marketing. You can do this by logging into My Account and amending your preferences or you can call our Customer Services Team.

You may also object to other processing when we rely on our legitimate interests as the basis for processing, but we do not have to stop the processing if we can demonstrate compelling legitimate grounds for the processing (taking into account our processing activities, the nature of our business and our legitimate interests) and that these grounds override your interests, rights and freedoms or in the event that we need the personal data for the establishment, exercise or defence of legal claims. To enable us to consider any objection we will need to know what specific interests, rights or freedoms relating to your particular situation you believe will potentially be put at risk by our processing. If we do stop processing your personal data (apart from for direct marketing purposes), this may affect our ability to trade with you.

Automated Processing

From time to time, in deciding whether to enter into a contract with you, or during the ongoing performance of a contract, we take decisions based on automated processing which produces legal affects or similarly significantly affects you, for example, deciding whether to offer a credit facility or assessing a fraud risk. We use data from a variety of sources in our automated processing for credit scoring and fraud decisioning and we use statistical methods to produce the results. This logic helps us understand the risk posed by individuals by placing a weighting on certain criteria which is then calculated to give an overall score.

There are a number of consequences of such automated processing:

• we may open a credit account and you can purchase goods and services using this credit account

• we may increase or decrease your credit limit from time to time

• we may decide to offer you other credit terms such as buy now pay later or interest free credit which will facilitate your purchase of goods and services

• we may refuse your application for credit or we may decide not to offer certain credit products which may have an impact on your ability to purchase goods and services from us. This is in line with our obligations as a responsible lender as we have to assess affordability for credit purposes and to protect customers from financial distress and difficulty

• we may conduct a further review or request additional information from you in relation to your request to purchase goods and services if our fraud decisioning highlights any issues

We also use automated processing in relation to the information we hold about you to make recommendations of products and services we think you would be interested in and to improve your experience when you visit our website by making it relevant and tailored to you.

Right to Portability

In certain circumstances, you can request that we provide to you your personal data in a commonly used format. If you wish to make such a request you can call our Customer Services Team.

Right to Complain to the Information Commissioner’s Office

You have the right to lodge a complaint with the Information Commissioner's Office and more details can be found on their website www.ico.org.uk.

Credit Applications

In order to process your application and during our relationship with you, 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. This 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.

We will use this information to:

• Assess your creditworthiness and whether you can afford to take the product

• Verify the accuracy of the data you have provided to us

• Prevent criminal activity, fraud and money laundering

• Manage your account(s)

• Trace and recover debts, and

• Ensure any offers provided to you are appropriate to your circumstances.

We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs.

When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders. A soft search quotation will not place a search footprint on your credit file.

If you are making a joint application, or tell us that you have a spouse or financial associate, 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.

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 at:

• TransUnion - www.transunion.co.uk/crain

• Equifax - www.equifax.co.uk/crain

• Experian - www.experian.co.uk/crain

These links will take you to the same document.

Fraud Prevention

Before we provide services, goods or financing to you, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you.

What We Process & Share

The personal data you have provided, we have collected from you, or we have received from third parties may include your:

• name

• date of birth

• residential address and address history

• contact details such as email address and telephone numbers

• financial information

• employment details

• identifiers assigned to your computer or other internet connected device including your Internet Protocol (IP) address

When we and fraud prevention agencies process your personal data, we do so on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also necessary to enable us to enter into and perform our contracts with you.

We, and fraud prevention agencies, may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

Automated decisions

As part of the processing of your personal data, decisions may be made by automated means. This means we may automatically decide that you pose a fraud or money laundering risk if:

• our processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct; or is inconsistent with your previous submissions; or

• you appear to have deliberately hidden your true identity

You have rights in relation to automated decision making: if you want to know more please contact our Customer Services Team.

Consequences of Processing

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services and financing you have requested, or we may stop providing existing services to you.

A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details above.

Data Transfers

Fraud prevention agencies may allow the transfer of your personal data outside of the UK. This may be to a country where the UK Government has decided that your data will be protected to UK standards, but if the transfer is to another type of country, then the fraud prevention agencies will ensure your data continues to be protected by ensuring appropriate safeguards are in place.

Your Rights

Your personal data is protected by legal rights, which include your rights to:

• object to our processing of your personal data

• request that your personal data is erased or corrected

• request access to your personal data

For more information or to exercise your data protection rights, please contact us using the contact details above.

You also have a right to complain to the Information Commissioner's Office, which regulates the processing of personal data.

More Information

If you have any queries about how we use your information or on data protection generally please call us or write us.

Opting Out

From time to time we may contact you with details on special promotional offers or products that we think you would be interested in, via email, telephone, SMS, or post or from specially selected third parties. If you do not want to receive these communications you can opt out in the following ways:

• Via My Account - Existing customers who have registered their account online – log into My Account, go to 'My Details' / 'Contact Preference' and tick each method of contact you wish to opt out of.

• By calling us or writing to us at the above address if you don’t have an account or your account isn’t registered online. Please state which contact method you wish to be removed from (existing customers should provide their Account Number). Please clearly state whether you wish to be removed from our marketing communications, marketing communications from Third Parties, or both.

• To opt out of marketing emails from us, click on the “unsubscribe” link contained at the end of marketing emails and follow the subsequent instructions.

• To opt out of app notifications or in app messages from us, then please go into your device settings and disable notifications.

• To unsubscribe from web notifications from us, please go to your browser settings and within ‘Site Settings/Options’, select ‘Notifications’ and ‘Block’ for our website.

Whilst we aim to make changes to your marketing preferences as soon as possible, we advise that you allow up to 1 month for any changes to take effect.