General Privacy Policy

We are Neyber Limited (referred to as “we” or “us” or “our” or “Neyber”)). We provide an online platform which provides access to financial products to employees or members of our clients.

Neyber is authorised and regulated by the Financial Conduct Authority (“FCA”) to enter into a regulated credit agreement as a lender, exercise, or have the right to exercise, the lender's rights and duties under a regulated credit agreement, to carry out credit broking, and debt adjusting activities, under reference number 718709.

Our registered address is at 1st Floor, 3 Finsbury Avenue, London, EC2M 2AR. We are a private limited company and our registered company number is 08806631. We operate from our registered address. We are not covered by the Financial Services Compensation Scheme.

Neyber is committed to protecting and respecting your privacy. This policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. For the purposes of the Data Protection Laws.

We are the data controller of any personal data you provide to us and are subject to any applicable data protection laws.

We are registered with the Information Commissioner’s Office (registration number: ZA039009).

Neyber works with employers to provide employees with access to financial wellbeing information and financial products. When accepting the financial products, customers agree to making payments or repayments by direct salary deductions. A direct debit is also required to be set up for use in the event that the customer ceases to be employed by the employer.

Contacting us:
If you have any questions about our privacy policy or your information, or to exercise any of your rights as described in this privacy policy or under data protection laws, you can contact us:

By post:
The Neyber Data Protection Officer,
1st Floor, 3 Finsbury Avenue, London, EC2M 2AR

By email:
The Neyber Data Protection Officer, contactus@neyber.co.uk

General

  1. Please read this privacy policy carefully as it sets out the basis on which we collect any personal information from or about you, and how we use it in the operation of the:

    • Neyber Platform, which is the online platform through which employees or members of our clients can apply for and manage their loans with us;
    • Neyber Client Portal, which is the online portal through which our clients allow a prospective customer to register with our website and to apply to become a borrower. This includes all areas of this website used for transmission of information between a client and us; or
    • Neyber.co.uk, which is Neyber’s public website.

    By visiting our website or by using the Neyber Platform or Neyber Client Portal you acknowledge the practices described in this privacy policy.

  2. This privacy policy covers:

    • anonymous visitors to our website (“Guests”);
    • borrowers or prospective borrowers; and
    • our clients (and their personnel).
  3. Please note that certain parts of this privacy policy only apply to borrowers and other parts only apply to clients. Where this is the case, we make it clear in the relevant paragraph.

  4. Clients may be limited liability companies, limited liability partnerships, unlimited partnerships, sole traders or unincorporated associations. In these circumstances, this privacy policy will apply to, and 'you' and 'your' refer to, the individuals who are you as the client, if a sole trader, or you as a director, partner, member, guarantor or employee of the client as appropriate.

  5. It may be that we also seek and obtain personal data about other parties linked financially with you. You should therefore ensure they read this privacy policy and you have their consent to disclose the information about them.

  6. If you have any questions about any aspect of this privacy policy or do not agree with it, please contact us at Customer Services, Neyber Limited, 1st Floor, 3 Finsbury Avenue, London, EC2M 2AR or support@neyber.co.uk before using our website.

  7. We may change this privacy policy from time to time by updating this page, and where appropriate we will notify you by email. You should check this page from time to time to ensure you are happy with any changes.

Neyber’s Privacy Principles

  • Neyber is committed to safeguarding the privacy and security of your information.
  • We will only collect and use your information where we have lawful legitimate business reasons to do so.
  • We will not ask for more information than we need for the purposes for which we are collecting it.
  • We will update our records when you inform us that your details have changed.
  • We have implemented and adhere to information retention policies relating to your information.
  • We will ensure that your information is securely disposed of at the end of the appropriate retention period.
  • We observe the rights granted to you under applicable privacy and data protection laws.
  • We will ensure that queries relating to privacy issues are promptly and courteously dealt with.
  • Our staff are trained on their privacy obligations.
  • We will ensure there are appropriate measures in place to protect your information regardless of where it’s held and ensure that safeguards are in place before transferring your information to other countries.

What information do we collect from Website users?

  1. You can browse our website as a guest without giving us any information, and we won’t know who you are. However, even if you are a guest, please bear in mind that we may:

    • record the areas of our website which you visit and at what times;
    • record information about your activities in using our website;
    • collect information about your computer, such as which browser you are using, your network location, your operating system, your IP address and the type of connection you are using (e.g. broadband, ADSL etc.);
  2. We collect the information above by using cookies. Please see our Cookies Policy which explains what cookies we use on our website, why we use them and how you can control them.

  3. Additional services are available once you register with us and login to our website. In this case, we will know who you are, your activities on our website and information about your computer may be linked to you on our systems. We may retain copies of any correspondence you send us, details of your registration history and any materials you post or upload on the Neyber Lending Platform or the Neyber Client Portal (for example payslips and other information we may require for salary verification purposes).

  4. We also store data that you submit to us via email, via our optional surveys, and through our contact form and email subscription sign-up form on our website.

What information do we collect from people applying for Neyber products?

  1. The types of information we may request from you are:
    • contact information – including your name, address, postcode and other contact information such as email address and telephone/mobile number;
    • your marital status and the number of dependents you have;
    • your residential status and address history;
    • your employer, employment and salary details;
    • the bank or building society account details and details of debit cards or credit cards used to make payments on the Neyber Lending Platform;
    • your passwords and security question answers;
    • your financial requirements;
    • answers to questions required by third party credit reference agencies for identification purposes; and
    • information about your activities in using our website.

What information do we collect from clients?

  1. The types of information we may request from you are:
    • your contact information – including your name, business address, postcode and other contact information such as your business email address and telephone/mobile number;
    • job title;
    • company name;
    • company registration number;
    • size of workforce;
    • company's industry;
    • employees’ salary payment date;
    • names and work email addresses of employees;
    • other employee or member information (including personal information relating to your employees and/or members) – see paragraph 5 below for further details;
    • information from directors/individuals associated with you and/or your business;
    • information about your activities in using our website.

Information collected from clients about their employees or members

  1. Clients will provide information about their employees or members to us (or one of our third-party service providers) as set out below.

    • Clients may provide the name and work email addresses of their employees or members to us so that we can invite them to register as a borrower on the Neyber Lending Platform.
    • Clients may provide employee or member information to us so that we can verify information provided by prospective borrowers via a loan application.
    • After a loan application is made, our client may provide personal information about their employee or member loan applicant to us so that we can verify the information provided during the loan application process. This will help us to decide whether or not to make an offer of credit and, if so, on what terms.
    • While a loan agreement is outstanding, our client may provide personal information about their employee or member borrower in order to update any information which may have changed since the loan application was made or to inform us that their employment or membership has or is due to come to an end or provide other information which may affect the terms of the loan agreement.
    • If repayments are missed, in order to help us assess the most appropriate course of action.
  2. Clients may transfer information about their employees or members through the Neyber Client Portal which is an online portal (“Data Portal”) operated by a third-party portal provider (“Portal Provider”). The Portal Provider will hold such information on behalf of the client and subject to the terms of a data protection agreement entered into between the client and the Portal Provider. When a loan application is made, we may access the information about you that is held on the Data Portal, in which case we will become a Data Controller of that information.

  3. The types of information we may receive about a borrower from our client are:

    • contact information – including your name, address, postcode and other contact information such as email address and telephone/mobile number;
    • your marital status and the number of dependents you have;
    • your residential status;
    • your employer, employment and salary details;
    • the bank or building society account details and details of debit cards or credit cards used to make or receive payments on the Platform;
    • your employment end date and notice requirements; and
    • other information which may affect your eligibility to apply for credit through the Platform.

Information from other sources

  1. We will check information about you held on our own records and also obtain information from credit reference agencies and other third parties about you and your financial associates’ personal credit behaviour and personal credit accounts.

  2. We will also search at fraud prevention agencies for information on you and your financial associates and business partners.

Information collected when you apply for a job.

  1. In completing our job application form or submitting your CV to us by email, you will give us personal information about yourself.

  2. We will use your personal data only for the purpose of assessing your suitability for employment by us and in any subsequent interviewing process. Copies of the information you submit, and any further correspondence will be retained in order to progress your job application and as a record of our employment and fair access processes.

  3. When you apply for a job with Neyber you will submit your CV to us by email. Your application will only be processed by our HR team based in the UK. The information you provide to us as a jobseeker is supplied in strict confidence and your personal information will be input onto a computer database for internal recruitment purposes only. Only employees of Neyber who are part of the recruitment and selection processes, or IT support contractors engaged by us, will have access to your information.

  4. We will not sell or disclose your personal information to any third party other than as set out in this privacy policy without your consent.

  5. We may store and record any telephone calls you have with Neyber staff for record keeping and quality control purposes.

  6. We take all reasonable steps to retain personal information only for as long as we need to process your job application. We may also retain your details after a decision has been reached regarding your suitability for current jobs for vacancies that may become available in the future, or in accordance with our legal obligations.

What do we do with the information we collect?

  1. We store and use this information to:

    • make our website available to you and to identify and provide details of the products and services which you may be interested in;
    • enrich your experience and interaction with our website by allowing you to store your details so that your preferences are retained when you revisit our website;
    • analyse site usage and improve our services;
    • deliver to you any administrative notices, alerts and communications relevant to your use of the services;
    • contact you from time to time to inform you about new features, to troubleshoot problems, and to help protect you against fraud or other criminal activity;
    • carry out financial and identity checks, fraud prevention checks, regulatory checks and credit checks, including by using scoring methods;
    • check details on applications for credit and credit related and other facilities;
    • manage your borrower or client account with us and update the records we hold about you from time to time;
    • (in respect of borrowers) if you do not repay money you have borrowed, to trace your whereabouts and recover debts or enforce a loan agreement;
    • (in respect of borrowers) to provide you, or permit your employer or member organisation to provide you, with information about goods or services offered by other companies that we and/ or they feel may interest you. You will be contacted by electronic means (email or SMS) only if you have consented to this;
    • carry out product development, statistical analysis and market research and to improve our products and services;
    • for customer service, including answering questions and responding to feedback and complaints;
    • for any other specific purposes in relation to your activities on the Neyber Lending Platform or the Neyber Client Portal.
  2. We may also use your data, in anonymised and aggregated form only, to carry out an analysis of and compile reports on the financial wellbeing of a client’s workforce or membership as a whole.

Who do we share your information with?

  1. We won't provide your personal information to other companies for their marketing purposes unless you have given us your consent. However, we may aggregate anonymised information based on your personal information and disclose this to advertisers and other third parties.

  2. We may share your personal information with companies and other third parties performing services on our behalf (for example credit reference agencies, the Portal Provider, customer relationship management providers or other service providers) who will only use the information to provide that service. We may also share your personal information with other members of our corporate group, or a purchaser or potential purchaser of our business. We may also share your information with online consumer review services, in which case, you may be asked to provide a customer review to help us improve our services.

  3. In some circumstances, we may have to disclose your personal information by law, because a court or the police or other law enforcement agency has asked us for it.

  4. We will not sell or disclose your data to any third party other than as set out in this privacy policy.

  5. Where it is necessary, or we have gained your consent, we may share your personal information with the following third parties for the provision of our service:

    • Equifax (credit reference agency)
    • CallCredit (credit reference agency)
    • Cloud Lending Solutions (loan management platform)
    • GoCardless (direct debit management platform)
    • ITM Limited (online portal provider)
    • Mailchimp (marketing automation platform)
    • Opos Limited (debt collection service)
    • PCA Predict (address validation service)
    • SalaryFits (online portal provider)
    • Salesforce (customer relationship management platform)
    • SendGrid (marketing communication platform)
    • TrustPilot (online customer review community)

Please note that this list may be subject to change.

  1. Loan applicants

    The personal data provided by loan applicants or received from third parties, for example, credit reference agencies, will be used to prevent fraud, money laundering and to verify the loan applicant’s identity in line with Neyber’s Fair Processing Notice.

    We may share a loan applicant’s and/or borrower’s personal information with their employer or member organisation for the purposes of:

    • checking details on applications for credit, credit-related and other facilities;
    • collecting money owed by the borrower under any agreement for credit through salary deductions;
    • recovering owed debts; and
    • providing the borrower with information about goods or services offered by other companies that we, your employer or member organisation feel may interest you. The borrower will be contacted by electronic means (email or SMS) only if he/she has consented to this.
  2. We may share relevant personal information with a loan applicant’s/ borrower’s employer or member organisation (such as contact details, date of birth, gross basic salary, start date of employment, payroll or membership number, and details of loan agreements or products purchased by the borrower which are to be processed via payroll), in order to provide our services to you and improve the accuracy of their respective records.

  3. In addition, we may disclose a borrower’s personal information to:

    • credit reference and fraud prevention agencies to perform similar checks, trace your whereabouts and recover debts you owe. This may include details of your loans or other credit facilities on the Neyber Lending Platform, how you manage them and any amounts outstanding;
    • debt collection agencies, security trustees and other legal representatives if required to enforce the terms of any loan agreement; and
    • a discretionary provision fund which may be set up for the purposes of compensating us or other lenders where you have failed to meet your repayment obligations under any loan agreement.

What credit reference and fraud prevention agencies do

  1. When you complete ‘Find my Rate’, we will submit a request to the credit reference agency to do a soft credit search. When completing this they will leave a “footprint” on your credit file. However this footprint will only be visible to yourself and Neyber.

  2. If you submit an application for a loan, we will perform a full credit search which will leave a visible credit search “footprint” on your credit file.A record of the full credit search will be seen by other organisations when you apply for credit in the future; and

  3. A credit reference agency will link together the previous and subsequent names advised by you, of anyone that is a party to the account.

  4. Credit reference agencies supply the following information to us:

    • information about you, such as previous applications for credit and similar personal credit information in your name or in relation to your financial associates and business partners, and details of any financial sanctions imposed by the United Kingdom government which are applicable to you;
    • public information such as County Court Judgments (CCJs) and bankruptcies;
    • electoral register information on you and your business partners; and
    • fraud prevention information.
  5. Credit reference agencies will keep records of outstanding debt on file for six years after they are closed, whether settled by you or defaulted.

  6. The information which we and other organisations provide to the credit reference agencies and fraud prevention agencies about you, your financial associates, your business partners and details about your business may be supplied by credit reference agencies and fraud prevention agencies to other organisations and used by them to:

    • prevent crime, fraud and money laundering by, for example checking details provided on applications for credit and credit related or other facilities;
    • check the operation of credit and credit-related accounts;
    • verify your identity if you, your financial associates or your business partner(s) apply for other facilities;
    • make decisions on credit and credit related services about you, your financial associates and/or your business partners, or your business;
    • manage your personal account(s), your financial associate’s account(s), your business partner’s and/or business credit or credit related account(s);
    • trace your whereabouts and recover debts that you owe;
    • conduct other checks to prevent or detect fraud; and
    • undertake statistical analysis and system testing.
  7. If false or inaccurate information is provided by you and fraud is identified, we will record this and details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information. We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:

    • checking details on applications for credit and credit related or other facilities;
    • managing credit and credit related accounts or facilities;
    • recovering debt;
    • checking details on proposals and claims for all types of insurance; and
    • checking details of job applicants and employees.
  8. Please contact us if you want to receive details of the relevant fraud prevention agencies.

  9. We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.

Where we store your personal data

  1. The data that we collect from you will be stored within the European Economic Area ("EEA") via our third-party providers. The personal data that we collect from you will also be copied, transferred to and stored at, a destination outside the EEA by such third-party providers to act as a back-up, should any of your data become lost, damaged or destroyed. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Disclosing information about other individuals

  1. If you are a joint applicant, or if you have told us of some other financial association that you have with another person (for example financial associates), you must be sure that you are entitled to:

    • disclose information about your joint applicant and anyone referred to by you; and
    • authorise us to search, link or record information at the credit reference agencies about you and anyone referred to by you.
  2. An association will be created by the credit reference agencies between joint applicants and between you and anyone you tell us is financially connected with you. This will link your financial records with that person and those records will be taken into account in all future applications either by you or both of you. This will continue until one of you successfully files a disassociation at the credit reference agencies, i.e. informing them that you are no longer connected financially with a particular individual.

Marketing and Communications

  1. We would like to provide you with information about our new products, services, promotions, special offers and other information which we think you may find interesting.

  2. If you have registered with us or have previously asked us for information on our products or services, provided you have given us your consent in the format set out in Annex 1 to this Privacy Policy, we may send you information on our range of products and services by phone, email and/or SMS.

  3. You have the right to object at any time to our processing of your personal information for direct marketing purposes and If you decide at any time that you no longer wish to receive marketing phone calls, emails or SMS from us, please contact us by email at support@neyber.co.uk or in writing to us at Neyber Limited, 1st Floor, 3 Finsbury Avenue, London, EC2M 2AR.

  4. Alternatively, if you have a Neyber account, please log in and update your notification preferences. We will always give you an opportunity to unsubscribe from receiving any marketing from us in each communication we send to you.

Your rights

Access to your information and updating your information

  1. You have the right to access information which we hold about you. If you so request, we shall provide you with a copy of your personal information which we are processing. For any further copies which you may request, we may charge a reasonable fee based on administrative costs. Please contact us by email at support@neyber.co.uk or in writing to us at Customer Services, Neyber Limited, 1st Floor, 3 Finsbury Avenue, London, EC2M 2AR.

  2. You also have the right to receive your personal information in a structured and commonly used format so that it can be transferred to another data controller (“data portability”).

  3. We want to make sure that your personal information is accurate and up to date. If you think any information we have about you is incorrect or incomplete, please email us at support@neyber.co.uk or in writing to us at Customer Services, Neyber Limited, 1st Floor, 3 Finsbury Avenue, London, EC2M 2AR. We will correct, delete or update any information as soon as possible.

Right to object

  1. Where we process your information based on our legitimate interests, you also have the right to object, on grounds relating to your particular situation, at any time to processing of your personal information which is based on our legitimate interests. Where you object on this ground, we shall no longer process your personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

Your other rights

  1. You also have the following rights under data protection laws to request that we rectify your personal information which is inaccurate or incomplete.
  2. In certain circumstances, you have the right to:
    • request the erasure of your personal information erasure (‘right to be forgotten’);
    • restrict the processing of your personal information to processing to which you have given your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of others.

Automated decisions – your rights

  1. We may use a credit-scoring system, i.e. an automated system to assess any aspect of your credit worthiness. You may ask us to ensure that, when we are evaluating your application for finance, we don’t base any decisions solely on an automated process. You must notify us of this request in writing to Underwriting Department, Neyber Limited, 1st Floor, 3 Finsbury Avenue, London, EC2M 2AR or contactus@neyber.co.uk.

  2. If you make such a request, you will then have the right to be notified where such a decision is or will be based on an automated process. If we notify you that we have taken such a decision, you may request us to review that decision other than by automatic means by writing to Underwriting Department, Neyber Limited, 1st Floor, 3 Finsbury Avenue, London, EC2M 2AR or contactus@neyber.co.uk within 21 days of receiving the notification.

  3. These rights will not apply in all circumstances, for example where the decision is authorised or required by law and steps have been taken to safeguard your interests.

Exercising your rights

  1. You can exercise any of your rights as described in this privacy policy and under data protection laws by contacting us as given in “Contacting us” above.

  2. Save as described in this privacy policy or provided under data protection laws, there is no charge for the exercise of your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested; or (b) refuse to act on the request.

  3. Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm your identity.

Security

  1. We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk.

Linking

  1. This website makes use of third party solution providers either via direct sourcing of data or via use of third party applications. Your use of those applications is subject to their own privacy policies, which may be amended from time to time. Our current third-party solution providers include but are not limited to:

    • GoCardless;
    • Send Grid;
    • Target Group;
    • Equifax;
    • Salesforce;
    • PCA Predict;
    • Conga;
    • Callcredit;
    • Firebase;
    • EPortal; and
    • Cloud Lending.
  2. Once you have left our website, we cannot be responsible for the content of other websites or for the protection and privacy of any information which you provide on these websites. Please note that these websites have their own privacy policies and website terms and conditions. We do not accept any responsibility or liability for these policies. Please check their privacy policies and their website terms and conditions when you visit them and before you submit any personal data to these websites.

Complaints

  1. You have the right to complain to the Information Commissioner’s Office (https://ico.org.uk/) about our data processing activities (helpline on 0303 123 1113)

Last updated: 30th May 2018

Get in touch

Got questions or need more information? Feel free to get in touch with us.

We're open Monday - Thursday 9am to 6pm, Friday 9am to 5pm. We are closed at weekends and on Bank Holidays. Call charges may vary.

Calls may be monitored or recorded for training or quality purposes.
Please note, we are not able to take applications by phone.

0800 820 3103

0203 744 0552

Financial wellbeing team: hello@neyber.co.uk

Support team: contactus@neyber.co.uk