Updated: 4 September 2018
Welcome to HappyPenguin.com's privacy notice.
HappyPenguin.com is a website owned and operated by Ready Money Capital Ltd, a company organised under the laws of England and Wales with Company Number 11158988 and registered with the Information Commissioner’s Office under Registration Number ZA441875.
Ready Money Capital Ltd respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
2. Important information and who we are
Purpose of this privacy notice
This privacy notice gives you information on how Ready Money Capital Ltd collects and processes your personal data through your use of this website, including any data you may provide through this website when you request an offer of credit from one of our trusted third party lender partners.
This website is not intended for children and we do not knowingly collect data relating to children.
Ready Money Capital Ltd is the controller and responsible for your personal data (collectively referred to as "T.UK", "we", "us" or "our" in this privacy notice).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Our full details are:
Data Protection Officer
Ready Money Capital Ltd
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 25 May 2018 and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notices. When you leave our website, we encourage you to read the privacy notice of every website you visit.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we will not be able to perform the contract we have or are trying to enter into with you (for example, to process a request for an offer of credit from our trusted third party lender partners).
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
– request an offer of credit from our trusted third party lender partners;
– request marketing to be sent to you;
– give us feedback.
– Technical Data from the following parties:
a. analytics providers such as Google based outside the EU;
b. advertising networks based inside and outside the EU; and
c. information processing providers based outside the EU.
– Identity and Contact Data from data brokers or aggregators based inside and outside the EU.
– Trusted affiliate websites, networks and third party lender partners.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or SMS. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To process your requests for offers of credit from our trusted third party lender partners|
Performance of a contract with you. This will include automated decision making on the part of our trusted third party lender partners.
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity|
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical|
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have provided us with consent to contact you and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the T.UK group of companies for marketing purposes. Marketing messages may relate to auto finance, banking, credit cards, credit references and scores, credit repair, insurance, payday loans, personal loans, payment protection insurance, shopping clubs and reward programs, and identity protection.
You can ask us or our trusted third party partners to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of requests for offers of credit from our trusted third party lender partners.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
We use the following cookies:
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
|subaccount, source, referrer, keyword, uuid|
These cookies enable us to determine how you and other users of HappyPenguin.com arrived at the site.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by using specific contractual clauses which give personal data the same protection it has in Europe.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other service providers who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are listed and described below:
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
– Other companies in the T.UK Group acting as joint controllers or processors and who are based in the EEA, the United Kingdom and the United States and provide IT and system administration services and undertake leadership reporting.
– Other companies in the T.UK Group acting as joint controllers or processors and who are based outside the EEA and provide software development and engineering services.
– Service providers acting as processors based in the EEA, the United Kingdom and the United States who provide IT and system administration services.
– Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based the United Kingdom and the United States who provide consultancy, banking, legal, insurance and accounting services.
– HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who may require reporting of processing activities in certain circumstances.
– Our network of trusted third party affiliate websites, third party affiliate networks, third party digital marketers, and third party lenders.