We have developed this notice because we want you to feel confident about the privacy and security of your personal information and because we would like to explain how we will use and process it. Shelby Finance Limited trading as ‘Dot Dot Loans’ (“we”, “us”, “our”) is your controller and abides by applicable data protection laws.
Shelby Finance Limited, trading as ‘Dot Dot Loans,’ is a subsidiary of Morses Club PLC.
When we refer to "personal information" in this Privacy Notice, we mean information which identifies you as an individual (whether on its own or in connection with other information that we hold about you). For example, your name, address, email address, phone numbers, and perhaps some less obvious details like a list of payments you already make. We hold, use and share data about you in your capacity as a consumer for the purposes mentioned in this Privacy Notice.
We have a Data Protection Officer who can be contacted by e-mail at DPO@Morsesclub.com, by telephone on 0330 045 0725 or by post at:
Data Protection Officer
Shelby Finance Ltd
Centre 27 Business Park
In addition please refer to the ‘Contact Us’ section (below).
Please read this Privacy Notice carefully. It explains clearly how we will use your personal information collected when you use our website and/or apply for, and are accepted for, a loan and as part of the other services that might be included as part of this process.
This Privacy Notice applies to how Dot Dot Loans deals with your personal information which is collected through our www.dotdotloans.co.uk website (our “website”), when you apply for a loan product or when we are otherwise in contact with you (for instance when you call us or email us). It does not apply to any other company or to any other company's websites even if you access them through Dot Dot Loans. If you disclose your personal information to other companies your information will be dealt with according to their own privacy policies and practices.
In the terms and conditions of your loan agreement you will see additional information about data protection, credit checks and how we use and share your personal information. For the avoidance of doubt, this Privacy Notice is our primary Privacy Notice and any additional items covered in your loan agreement should be considered as supplemental.
You may also be required to enter into terms and conditions associated with each of our services you use (for instance, we will ask you to sign terms and conditions which are in a loan agreement if your application for a loan is successful).
We collect the following personal information about you:
|Category of Personal Data:||Collected From:|
|Your full name and initials*||You - Completing the loan application form or contacting us Brokers and other providers of loan products|
|Your postal address(es)*||You - Completing the loan application form or contacting us Brokers and other providers of loan products|
|Your date of birth*||You - Completing the loan application form or contacting us Brokers and other providers of loan products|
|Your marital status*|
|Your contact telephone numbers (daytime and evening)*|
|Your e-mail address*|
|Your IP Address*||From your use of our Website|
|Your Country of Location*||From your use of our website|
|The amount of time on our website*||From your use of our website|
|Device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. This is your personal information because it all links to your IP address. Hotjar stores this information on our behalf in a pseudonymized user profile.
For more information about the processing of this personal information – see references to Hotjar at the end of the table in Section 3 below.
|From your use of our Websites (and the U Account mobile app)|
|Your employment details*||You - Completing the loan application form or contacting us|
|Your salary details (Including pay date frequency)*||You - Completing the loan application form|
|Details of your non-salary income||You - Completing the loan application form or contacting us|
|Details of your regular or one-off expenses*||You - Completing the loan application form or contacting us|
|Your requested loan amount and term*|
|The reason for your loan*|
|Details of your payment history for (previous or current) loans taken with Dot Dot Loans*||Our records of your previous or current loans with us|
|Your credit status and history (including the information set out in Section 4 below)*||Credit reference agencies and fraud prevention agencies|
|Your history of name changes*||You - Completing the loan application form or contacting us. We will also receive information about your history of name changes from Credit Reference Agencies (see “Credit Checking and Account Management” below)|
|Your postal address history*||You - Completing the loan application form or contacting us. We will also receive information about your history of name changes from Credit Reference Agencies (see “Credit Checking and Account Management” below)|
|Bank Account Details* - applicable to our short-term loans||You - Completing the loan application form or contacting us|
|Bank Account Details* - applicable to our long-term loans||At the loan application stage - third party income and expenditure verification service via Open Banking at the application stage (see “Our use of Open Banking for long-term loan applications” below) During your loan – you contacting us|
|Bank Account balance and incoming and outgoing transactions for the last six months* – applicable to our long-term loans||Third party income and expenditure verification service via Open Banking (see “Our use of Open Banking for long-term loan applications” below)|
|Debit Card Details*||You - Completing the loan application form or contacting us|
|The number of children or dependents in your household||You - Completing the loan application form or contacting us|
|Your residential status (whether you own or rent your home)*||You - Completing the loan application form or contacting us|
|Details of whether you have any special needs or are otherwise vulnerable*||You - Completing the loan application form or contacting us|
|Your marketing preferences||You - Completing the loan application form, or contacting us, or where we have written to you and in that way captured your marketing preferences.|
|Your signature*||You - Completing the loan application form or contacting us|
|Your comments or other information entered into via our “Contact Us” page, any customer satisfaction surveys and/or in any correspondence between us||You - Completing the loan application form or contacting us|
* The processing of these categories of personal data is mandatory in order for us to assess your eligibility for a loan and to enable us administer the loan during its term. A failure to provide this information may result in us being unable to offer you our products and services.
If we have purchased your loan agreement from another provider we will have obtained your personal information from that other provider (instead of from You). This will have been explained to you in the ‘welcome letter’ we addressed to you.
We will use your personal information in the following ways:
|Purpose||Categories of personal data||Lawful basis for processing|
|To verify your identity, credit standing and income and expenditure and to enable us to consider and process your application for a loan or other products or services.||All categories of personal data set out in Section 2 above except your marketing preferences.||This processing is necessary for the performance of our contract with you. This processing is necessary for compliance with legal obligations to which we are subject. In relation to verifying your credit standing and income and expenditure, our processing is also necessary for our legitimate interest of making sure that we enter into loan agreements with customers whose credit history does not expose our business to undue risk and our legitimate interest of acting as a responsible lender.|
|To assess your credit history and confirm your employment details (as explained further in Section 4).||All categories of personal data set out in Section 2 above and Section 4 below except your marketing preferences.||This processing is necessary for the performance of our contract with you. This processing is necessary for compliance with legal obligations to which we are subject. In relation to assessing your credit history, our processing is also necessary for our legitimate interest of making sure that we enter into loan agreements with customers whose credit history does not expose our business to undue risk and our legitimate interest of acting as a responsible lender.|
|To perform actions in line with the contract we have with you (in particular, the loan agreement) including administering, servicing your account with us and setting up payments.||All categories of personal data set out in Section 2 above.||This processing is necessary for the performance of our contract with you.|
|To collect unpaid loans and debt that may be owed by you to us.||All categories of personal data set out in Section 2 above except your marketing preferences.||This processing is necessary for the performance of our contract with you.|
|To develop, manage and market products and services to meet your needs, to determine your eligibility for different products and services that you may be interested in and notify you about changes to our website, our services or our products.||All categories of personal data set out in Section 2 above.||This processing is necessary for our legitimate interests of creating new or updated products and services to improve our service offering to existing and potential new customers.|
|To communicate with you to provide you with information about the products and services that you request from us or our other products and services which we would like to tell you about (including for direct marketing purposes if you have opted in by giving your consent, or if you have not opted-out after we have given you an opportunity to do that).||All categories of personal data set out in Section 2 above.||This processing is necessary for our legitimate interests of marketing new and existing products and services to existing and new customers. Where necessary for direct marketing purposes, we will process your personal data with your consent. If you are asked to give an opt-in consent this means we rely on the lawful reason of consent for our marketing. Sometimes consent is not necessary for our direct marketing and in those cases we will do our marketing based on the lawful reason of legitimate interests. In all cases you can object at any time to our direct marketing, or stop our marketing. For the simple way to stop our marketing see section 12 below. You can also find out about how to object by using your rights under data protection law. See section 9 below.. Marketing from us (Shelby) about products and services provided by Morses Club PLC will only happen with your opt-in consent. Marketing from Morses Club PLC to Shelby customers will only happen with your opt-in consent. You can object to or stop marketing from Morses Club PLC at any time and to do this you should use its own contact details which will be in the marketing communication itself.|
|Customer satisfaction surveys to monitor and improve the quality of our product and service offerings (which may involve using your data in quality and performance training).||Your full name and initials; postal and correspondence address(es); contact telephone numbers; e-mail address; comments or other information entered into via our “Contact Us” page, any customer satisfaction surveys and/or in any correspondence between us.||This processing is necessary for our legitimate interests of assessing our performance levels and evaluating new ways to improve our products and services.|
|To undertake market analysis, forecasting, business planning and auditing exercises in connection with our business.||All categories of personal data set out in Section 2 above.||This processing is necessary for our legitimate interests of management planning and forecasting in relation to our business.|
|To contact you in connection with any enquiries that you raise.||All categories of personal data set out in Section 2 above.||This processing is necessary for our legitimate interests of responding to questions and comments raised by individuals that contact us.|
|To detect, prevent and investigate actual and potential fraud and related activities. (We may use social media sites to check information you have supplied us)||All categories of personal data set out in Section 2 above.||This processing is necessary for compliance with legal obligations to which we are subject.|
|To comply with laws and our regulatory requirements.||All categories of personal data set out in Section 2 above.||This processing is necessary for our legitimate interests of complying with laws and regulatory requirements.|
|To, establish, defend, exercise, enforce or to protect our rights, property or safety, or that of our customers, employees or other persons with whom we have a business relationship.||All categories of personal data set out in Section 2 above.||This processing is necessary for our legitimate interests of establishing, defending, exercising, enforcing or protecting our rights and others with whom we have a business relationship.|
|For monitoring and recording of telephone calls and email communications where necessary for compliance with regulatory rules or self-regulatory practices or procedures relevant to our business, to prevent or detect crime, for quality, training and security purposes.||All categories of personal data set out in Section 2 above.||This processing is necessary for our legitimate interests of complying with regulatory rules and ensuring we are implementing quality checking and compliance processes.|
|To anonymise your personal data for market research, statistical and analytical purposes, including producing statistical research and reports||All categories of personal data set out in Section 2 above.||This processing is necessary for our legitimate interests of creating anonymous data sets that we can use for research, statistical and analysis purposes.|
Hotjar is forbidden to sell any of the data collected on our behalf.
We have configured the Hotjar service so that it does not collect key personal data you provide when applying for one of our products, such as your name, address, bank account details and information about your employer.
You may opt-out of Hotjar collecting your information when visiting our Websites and the U Account mobile app at any time by visiting Hotjar’s opt-out page at https://www.hotjar.com/opt-out and clicking 'Disable Hotjar'. You will need to do this on each browser you use. Alternatively, you can prevent Hotjar from collecting your information by activating the “Do Not Track” setting in your browser, which will also opt you out of similar services that use this setting to disable tracking.
|Device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. This is your personal information because it all links to your IP address.||This processing is necessary for our legitimate interests of analysing users’ activities on our websites and their devices (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like). This allows us to build a better user experience and service for our customers.
Where we process personal data relating to whether you have any special needs or are otherwise vulnerable, we will process this only:
If you apply for a loan we will use credit scoring and other automated systems to assess your application and verify your identity.
Our automated systems are used to make a recommendation to our loan application about whether you should be accepted for a loan. These systems compare the information in your application form and gathered from credit reference agencies to assess the risk of non-payment if we were to grant you a loan. They do this by processing your name, addresses, date of birth, employment status, salary, details of your non-salary income, details of your regular or one-off expenses, requested loan amount, reason for your loan, previous payment history, and credit status and history and comparing it against our customer database to evaluate whether you are likely to be able to repay your requested loan amount.
Step 1: Previous customers and applicants: If you have previously applied for a loan, and been declined, within a period of 30 days prior to your current application, our systems will decline your application. If you are a previous customer of Dot Dot Loans we will check our database to see whether you made your repayments. If you did not make your repayments on a previous loan, your application will be declined. If you did make your repayments, your application will pass to Step 2.
Step 2: Credit Reference Agencies: Our automated systems gather information from Credit Reference Agencies (see below for more information) about your credit score and credit history. The systems check this information against our bespoke scorecards to generate a suitability score for your application. If you do not meet the minimum suitability score then your application will be declined. If you exceed the minimum suitability score, the systems will use the credit score and credit history information to determine the maximum loan value that Dot Dot Loans will be able to offer you.
If your application satisfies Step 1 and Step 2, a final decision as to whether to accept your loan application and the value that Dot Dot Loans may loan to you is made by a member of our team.
You have a right to request that your application is reviewed by a member of our team, to express your point of view on the decisions that we make about you and to contest our decisions.
We will check your records through one or more credit reference agencies (“CRAs”) when considering your application. CRAs supply us with details of your credit history and associated information as well as information from the electoral register which is used to verify your identify and your residence.
When CRAs receive a credit check search request from us, they will always record details of this search and this means they will place a search ‘footprint’ on your credit file. That footprint will be seen by other lenders and persons unrelated to us (i.e. the other customers of the CRAs) if they undertake credit checks on you in the future in connection with their own financial products and services; we will carry out “soft” searches at the CRAs after the full credit check searches if we need additional verification of your identity after receiving the result of the full credit search and if we do this no-one else except you would see that we have made this additional enquiry.
We will provide information about this agreement and your repayment performance to all of the CRAs. We report to these third parties at least once a month, including details of the payments you make, payments that you do not make on time and details on any default against this agreement. Our records will remain on your credit file for 6 years after they are closed, whether settled by you or defaulted by us.
The personal data that we will share with CRAs include your:
The CRAs can also share your information with other organisations.
CRAs will provide us with the following information relating to you:
We and those other companies will use these records and other information to make credit decisions about you. The CRA records will also be used to make credit decisions about your current spouse, partner or other individual that has been financially linked or associated with you (for example if you have a joint account with them). We will: search, link and/or record information at CRAs about you both; link any individual identified as your financial associate, in our own records; take both your and their information into account in future applications by either or both of you (as relevant), and continue this linking until one of you notifies us that you are no longer linked; links between all such persons will remain on your and their files at the CRAs until such time as you or the other relevant person successfully files for a disassociation with the CRAs. If your circumstances change such that you are no longer a financial unit with another person, you should contact the CRAs directly using the contact details in the “How to find out more about Credit Reference Agencies” section below.
More information about CRAs and how they use personal data is available at the following links:
You can contact the CRAs currently operating in the UK; the information they hold will not be the same so it is worth contacting them all separately.
In order to be able to submit an application for one of our long-term loans (18 to 48 months), you will need to consent to our use of consents.online, a third-party Account Information Service Provider (AISP). Consents.online is an FCA regulated service that lets you grant us permission to view the information that appears on your bank statements through “Open Banking”. This is a paper-free way of you sharing your income and expenditure information with us so that we can thoroughly and fairly assess whether you can afford to take out a loan. It also removes the need for you to send bank statements, payslips or other income and expenditure-related information to us.
As part of the long-term loan application process, we will direct you to consents.online, who will ask you to provide your first and last name, email address and phone number. You will then be asked to select which bank/building society you hold your current account with before being asked for your consent to access the following account information and share it with Shelby Finance Ltd, trading as Dot Dot Loans:
Once you have consented, a secure, encrypted connection will be made with your bank/building society and you will be asked to authenticate yourself in the same way as you would to access your online banking log in. Your bank/building society will then ask you to confirm that you would like to share your account information with consents.online before this is passed to them, who will then share it with us.
You will only be providing consent to consents.online accessing this information and sharing it with us on a one-off basis and we will be limited to read-only access and cannot make any changes to your bank account. We will not ever share this information with any other third party.
You can withdraw your consent to this service at any time by contacting consents.online by email at email@example.com or telephone on 0800 180 8570. Withdrawing your consent means that consents.online will delete their record of your statement data and we will no longer be able to access it.
We will use this information as part of our credit and affordability checking processes, which includes verifying your income and expenditure, in order to decide whether we can offer you a long-term loan. We will notify you of the outcome of this review within one working day.
If you do not agree to consents.online supplying us with your bank account information via Open Banking, you will not be able to complete your long-term loan application and we will not be able to consider whether we can enter into a contract with you to provide you with this kind of loan.
When consents.online uses your personal information, it will be acting as a controller of that information. It will process your information in its own name as it has the sole mandate for that (which means it takes all decisions in relation to its own use of your personal data and we have no control over its use of your personal data). Please read consents.online's privacy notice for more information about how it will process your personal data as a data controller. You will be able to view this once we direct you to consents.online's website towards the end of your application.
In addition, as a normal part of our business we will share your details with:
Where we have received your personal details from a broker or another provider of loan products, we will notify such broker or loan provider whether you are eligible for a loan application with us and whether you have obtained a loan from us.
We will disclose your personal data to third parties if we are under a duty to disclose or share your personal data in order to comply with any laws, regulations or good governance obligations, or in order to enforce or to protect its rights, property or safety, or that of our customers or other persons with whom we have a business relationship. These third parties will include (without limitation) the police, Action Fraud, the National Crime Agency, HMRC, HM Treasury and the Department of Work & Pensions.
In the event that we sell any part(s) of Shelby Finance Limited or Morses Club PLC (a company in our group), we will also disclose your personal data to actual or potential purchasers of parts of its business or assets, and their respective advisers and insurers for our legitimate interest of restructuring our business in that particular way and also for the potential purchaser’s legitimate interests of:
For a short period we need to use a Curo group company in the United States for some services. This means your personal data is being hosted in the United States under the Privacy Shield certification regime. Data protection law permits transfers to organizations who are Privacy Shield certified. This processing in the United States will cease as soon as your personal data is migrated fully to our own systems and we expect this to happen before June 2019.
We will not transfer your data out of the European Economic Area (EEA) to any country that has been deemed (by the Information Commissioners Office) to have inadequate data protection controls except where we make those transfers lawful under data protection law by using appropriate safeguards such as EU Model Clause contracts (you can contact us for copies or more details) or based on US Privacy Shield. We will always make sure transfers of your personal data outside the EEA by made by ourselves are in accordance with data protection law.
If you take out a loan with us, we will retain your personal data for the period during which your loan remains outstanding and thereafter until the expiry of a period of seven years.
If you submit an application for a loan and your application was unsuccessful, your personal data will be held by us for up to 4 years.
If you complete a customer satisfaction survey, your personal data in relation to that survey will be held by us for a period of up to 6 months from the date that you submitted the survey response.
If you raise a complaint or there is a dispute between us, your personal data will be held by us for a period of up to seven years following the resolution of the complaint or dispute.
If you raise a general enquiry with us (which does not involve a complaint or dispute), your personal data in relation to that enquiry will be held by us for a period of up to one month.
We will retain your personal data for longer than the periods specified above if required by law, to defend or exercise legal rights (such as defending legal claims) or to comply with regulatory obligations.
It is important to us that you are in control of your own information. As a result, we offer the following controls:
The Right Of Access. You may request access to or copies of the personal information that we hold about you(known as a “Data Subject Access Request”) as set out in the “How can I find out what personal information Dot Dot Loans holds about me?” section below. If you would like to exercise this right, please contact us (as set out in the “Our Contact Details” section below).
The Right To Rectification. You have the right to have inaccurate information about you corrected. For more information, see the “How can I change the personal information Dot Dot Loans holds about me?” section below.
The Right To Erasure. You may request that your personal information be deleted where it is no longer necessary for the purposes of which it is being processed and provided there is no other lawful basis for which we may continue to process such personal information. If you would like to exercise this right, please contact us (as set out in the “Our Contact Details” section below).
The Right To Data Portability. Where you have provided us with your personal information that we process using automated means, you may be entitled to a copy of that personal information in a structured, commonly-used and machine readable format. If you would like to exercise this right, please contact us (as set out in the “Our Contact Details” section below).
The Right To Object. In some circumstances, you may, on grounds relating to your particular situation, have grounds to object to our processing of your personal information. We will consider any objections to its processing on the particular circumstances relating to each case. This includes (as one example) the right to object to your personal information being used for direct marketing by us. If you would like to exercise this right, please contact us (as set out in the “Our Contact Details” section below).
The Right To Restrict Processing. You may also request that we restrict the processing of your personal information to that to which you have consented or for the establishment, exercise or defence of legal claims or the protection of the rights of another person:
If you would like to exercise this right, please contact us (as set out in the “Our Contact Details” section below).
Your right to access, as detailed above, or to obtain copies of your personal information may extend to (but is not limited to) some or all of the following items below.
We will endeavor to return your details from 1 month of receiving the request.
A Data Subject Access Request is free. However, where a request is manifestly unfounded or excessive, we may require a reasonable administrative fee or refuse to act on the request. This will be based on the true administrative cost and will be discussed with the requester on application.
You can make a Data Subject Access Request or exercise your other rights by contacting us (as set out in the “Our Contact Details” section below).
Please tell us if your personal information, including contact details or address, change at any time so that we can update our records. If some of the information we hold about you is inaccurate (for instance because you have changed your marital status or name, or moved house, or changed your telephone number or email address) or incomplete, please contact us (as set out in the “Our Contact Details” section below). We will take steps to seek to correct or update any information if we are satisfied that the information we hold is inaccurate or incomplete. In certain circumstances, you may also request that we restrict our processing.
If you have given your consent (i.e. you are opted-in to our marketing) or if you have not opted-out after we gave you the opportunity to do that (this is relevant if our marketing is based on our legitimate interests which are described in section 3 above) you will receive direct marketing communications from us. For instance when you submit your name and contact details through our website, or when you apply for a loan, or when we write to you, this is usually when we capture your marketing preferences.
We may contact you by post, SMS, telephone or email in this way.
To change your marketing preferences, you can contact us using our contact details [set out in our Contact Us page] [set out below]. We will process your request within a reasonable period of time.
Any marketing communication by email or SMS which are from us will also include details of how you may unsubscribe.
We are serious about guarding the security of your personal information and the details of any transactions or applications made. We use the triage of Confidentiality, Integrity and Availability (CIA) as the keystones to our technical and organisational controls. This helps us protect against unauthorised or unlawful processing, accidental loss, destruction of, or damage to, your personal information.
If you require a printed copy of this Privacy Notice or a copy in another format such as audio or Braille, then please contact us using the contact page.
You can contact us by telephone on 0333 240 1370, by emailing us at firstname.lastname@example.org or by writing to us at Dot Dot Loans, Kingston House, Centre 27 Business Park, Birstall, Batley, WF17 9TD.
Last updated: 05/02/2020
Borrow £300 over 3 months with monthly repayment of £153.63. Total amount payable £460.89. Interest rate 292% p.a. (fixed). 1255% APR Representative.
Borrow £2500 over 24 months with monthly repayment of £198.68. Total amount payable £4768.25. Interest rate 71.1% p.a. (fixed). 99.9% APR Representative.