Version 1.2 – 25th October 2023
Who are we?
We are Molo Tech Ltd (“we”, “our”, “us”) and operate under the name of Molo and Molo Finance.
Please read the following information carefully. If you have any questions about your personal information please chat with us through our web chat, or by emailing us at firstname.lastname@example.org, or by writing to us at Data Protection Officer, Molo Tech Ltd, 84 Eccleston Square, Pimlico, London SW1V 1PX.
We’re registered with the Information Commissioner’s Office under number ZA310806.
At Molo we are committed to protecting and respecting your privacy, being completely open and transparent in the way we collect or obtain your personal information and how we treat that information.
For the purposes of applicable data protection legislation, we are a data controller in respect of the information that we collect or obtain about you. This is because we determine why and how your personal information is processed.
The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money laundering, and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found in this policy.
Personal data collected on our Website
Why we process your personal information
We process your personal information for a variety of reasons, upon different legal bases, depending on the reason for which we have collected or obtained your personal information. The main types of processing that we carry out and the legal basis for doing so are as follows:
We process your personal information in order to consider and process your application. This is necessary in order to take steps at your request before we enter into an agreement with you and is also necessary for our legitimate interests (i.e. in deciding whether or not we can offer you the product you have applied for). This type of processing is required in order for you to enter into an agreement with us. If you do not provide it, then we won’t be able to proceed with your application. In respect of fraud searches and identity verification, this processing is necessary for our legitimate interests (i.e. the prevention of fraud and money laundering) and compliance with our legal obligations.
Before we make a decision on your mortgage offer, we check your personal data against third party databases, for the purposes of preventing fraud and money laundering, and to verify your identity.
If your application is accepted, we will process your personal information in order to administer your account in a number of ways. This will include, for example, collecting loan repayments; providing you with account statements, notices, and other information such as changes to your interest rate; managing any arrears on your account; enforcing any security that we have in place; and dealing with any queries or complaints that you may have. This type of processing is necessary for the performance of our contract with you and in order to fulfil our legal obligations.
We will also process your personal information to manage our business operations, for example, our internal governance functions, which will include monitoring communications and activities in relation to your account (see further detail in relation to monitoring communications below), and for accounting and audit purposes. We have legitimate interests in doing so (i.e. it is necessary for our business and compliance purposes) and we may also have legal obligations to fulfil.
If your application is declined, we will store your personal information in accordance with our record retention procedures and to comply with our legal obligations. For further details, please refer to the section entitled “How long your personal information will be stored for” within this policy.
If we are dealing with a request you have made in order to exercise your legal and regulatory rights (including those referred to in the ‘Your rights under applicable data protection law’) below, this will be done in order to fulfil our legal obligation to respond to you.
We process your personal information for marketing purposes. This is necessary in order to fulfil our legitimate interests of providing you with information about products and services that you may be interested in.
Any consent that you give us will be as easy to withdraw as it was to give. Withdrawing your consent does not affect the lawfulness of any processing which occurred prior to the withdrawal of consent. If you do this, and if there is no alternative legal basis upon which we may process your personal information for a particular purpose, then this may affect what we can do for you.
How we collect and obtain your personal information
Credit reference checks
Automated decision making
Your rights under applicable data protection law
The right to be informed
We have provided this Privacy Statement to provide you with concise, transparent, intelligible and easily accessible information about how we use your personal data, including specific information depending on whether or not we have obtained your personal data directly from you.
Right to access
You have the right to access the personal information held about you and to obtain certain prescribed information about how we process it. This is more commonly known as submitting a ‘data subject access request’. We may request proof of your identity before sharing such information.
Right to rectify your personal information
If you discover that the information we hold about you is inaccurate or incomplete, you have the right to have this information corrected.
Right to be forgotten
You may ask us to delete information we hold about you in certain circumstances, this is often referred to as the ‘right to be forgotten’. This right is not absolute and only applies in certain circumstances. It may not therefore be possible for us to delete the information we hold about you, for example, if we have an ongoing relationship or are required to retain information to comply with our legal obligations to exercise or defend legal claims.
Right to restriction of processing
In some cases, you may have the right to have the processing of your personal information restricted. For example, where you contest the accuracy of your personal information, it may be restricted until the accuracy is verified, or where the processing is unlawful but you object to it being deleted and request that it is restricted instead.
Right to data portability
You have the right to receive, move, copy or transfer your personal information to a controller which is also known as ‘data portability’. You have the right to this when we are processing your personal information based on consent or on a contract and the processing is carried out by automated means. You should note that this right is different from the right of access (see above) and the types of information you can obtain under the two separate rights may be different.
Right to object to processing
You may object to the processing of your personal information (including profiling) when it is based upon our legitimate interests. You may also object to the processing of your personal information for the purposes of direct marketing (including profiling to the extent it relates to direct marketing) and for the purposes of statistical analysis.
Rights with respect to automated decision-making and profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. You can object to your personal data being used in this way. We are permitted to use automated decision-making and profiling if the decision: (a) is necessary for entering into, or performance of, a contract between you and us; (b) is authorised by EU or a member state law to which we are subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or (c) is based on your explicit consent. Where we engage in automatic decision-making or profiling in connection with a contract between us or further to your explicit consent, we implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention from us in the course decision-making process, and the opportunity to express your point of view and to contest the decision.
Molo is committed to protecting the privacy needs of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. Molo does not knowingly collect information from children under the age of 16 and Molo does not target its Website or any of its services to children under the age of 16.
Keeping your personal data secure