Privacy Policy Last updated 27 January 2021

myfreedom, Fusion Score and Aro are trading styles of Aro Limited. We are authorised and regulated by the Financial Conduct Authority (FRN: 662079).

Our registered office is Aro Ltd, Atlantic House, Atlas Business Park, Simonsway, Manchester, M22 5PR. Registered in England: 06297533. Our Data Protection Register number is Z120757X.

Aro Limited will be the data controller for the data that you provide us with or we collect in relation to the provision of our Services to you (as defined in our myfreedom terms and conditions)

We respect your privacy and protecting your data is paramount. We want you to be informed and empowered with respect to your privacy when you use our services. Please read this Privacy Policy carefully before using our Services. Together with our Terms and Conditions, this Privacy Policy sets-out our views and practices regarding your personal data, how we collect, process and treat it, and the rights you have in relation to the protection of your personal data.

By using our Services you are accepting and consenting to the practices described in this Privacy Policy, which we may update at any time.

THE INFORMATION WE COLLECT

Information you give us. You may give us information about you when you use our services and when you communicate with us. This includes information you input during registration by answering specific questions on our site, applying for a loan or credit card, receiving advice on ways to repay your debts, providing us with feedback, participating in surveys, and when you can you report a problem.

Personal data collected, used, stored and transferred by us may include:

• Your name and identity data, including forenames, last name, maiden name, date of birth, gender, marital status or similar identifier).
• Contact data including home address, email address, telephone number and your residential status.
• Employment status.
• Financial information (including bank statements, payment card details, savings, debts such as loans and credit cards, income & expenditure, employer & pension benefits, and other assets)
• Technical Data including internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices used to access the Freedom Finance Ltd website.
• Your banking provider(s).
• Monthly expenditure.
• Insurance products you hold.
• Family and dependents.
• Your aspirations (e.g. to buy a car).
• Personal information or documents required to identify you.
• Profile and Usage Data including feedback and survey responses, and how you use our website, products and services.
• Marketing and Communications Data including your preferences in receiving marketing from us and our business partners and your communication preferences.
• Special Category Data such as medical or health conditions may only be collected with your explicit consent.

Information that we may receive from your bank. You have the option to link your myfreedom Service with your bank, in which case your bank may share with us information about you which could include:

• Your bank account type and details
• Account number and sort code
• Account balance
• Bank account transactions (incoming and outgoing)
• Card transactions (incoming and outgoing)
• The fees, charges and interest you pay
• The benefits, services, rewards and interest your account offers

Special categories of data. The categorisation of some of your transactions may include special categories of data as it may be indicative of your political beliefs (e.g., if you pay for membership for a political party).

Information we collect about you. We will collect information during your use of the myfreedom Services including: (a) the details regarding the communications made between us; (b) technical information including the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; (c) information about your visit (including date and time); (d) products you viewed or searched for; (e) page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Recording telephone calls and other communications. We may monitor or record telephone conversations or other communications between you and us. These may be used for staff training and monitoring purposes.

Information collected from cookies. We and our service providers collect information about your use of our app from cookies. For more on how we use cookies and how to decline them or turn them off please read our cookie policy below.

HOW DO WE COLLECT YOUR PERSONAL DATA?

Personal data is collected by us using the following methods:

• Direct contact with our staff by phone, email, webchat, post or otherwise for example; for the purpose of applying for & processing loans, confirming identity, handling complaints etc.
• Automated technologies or interactions with our website, by using the web enquiry form or the find a loan function for the purpose of; processing identity, loan application etc.
• Third parties or publicly available sources such as credit reference agencies, Lenders, couriers, third party & partner websites.
• Open Banking and data collection from your nominated bank account.

HOW WE USE THE INFORMATION

We will use the information we hold about you to provide our myfreedom Service to you and improve our services, administer your account and communicate with you and to use information on an anonymous basis for research, profiling and analytical purposes.

Information you give us, or we collect from other third parties. We will use this information to:

• Provide you with information, products and services.
• Analysing and reporting on your account and transaction data that we obtain from your bank.
• Verify your identity as part of our identity authentication process.
• Notify you about changes to our services.
• Ensure that content on our site is presented in the most effective manner for you and your device.
• Aggregate it on an anonymous basis with other data for data analytical and reporting purposes.
• To ensure compliance with your requests for the exercise of your rights.
• To manage our communications in relation to your queries or complaints.

Information we collect about you based on your use of our site. We will use this information to:

• To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
• To improve the services we provide to you.
• Continually improve our ability to keep our products safe and secure and to prevent fraud.

Data analytics. We will use the information we hold about you to conduct analysis of it for the following purposes:

• Analysis of information about you on a personalised or aggregated basis to further tailor the experience to you.
• Verify the accuracy of data that we hold about you and create a better understanding of you as a myfreedom customer.
• To provide you with a better service by conducting statistical analysis and system testing to understand your needs.
• Network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access.

What we will never do. we will never sell your information to third parties.

Information we receive from other sources. We may combine this information with information you give to us and use this information and the combined information for the purposes set out above.

Recording telephone calls and other communications. We will use telephone recordings or transcripts of communications to check your instructions to us, analyse, assess and improve our services, for training and quality purposes and for the purposes of investigating any complaint you may make, or as evidence in any dispute between you and us.

WHO WE MAY SHARE YOUR DATA WITH?

We may share your data with lenders or service providers who you ask us to provide an eligibility quotation. Occasionally we may share your data with other third parties, such as a lender you select, a debt management company or Insolvency Practitioner if you select that service, other service providers, Credit Reference Agencies and Fraud Prevention Agencies.

We may need to disclose your data to others to ensure the smooth provision to you of our Services and any information you request. Your data may be disclosed to the other entities as described below.

Sub-processors. We may share your information with the following sub-processors:

• Equifax (Credit Reference Agency)
• Experian (Credit Reference Agency)
• consents.online (Account Information Services Provider)
• Aryza UK Services Limited (provider of the software we use to provide advice on clearing your debts)

• Capital One plc (credit card eligibility checker and provider). For further information on how Capital One plc use your data, view their Privacy Policy: https://www.capitalone.co.uk/web/privacy-statement.jsf

Group company. We may share your personal information with any member of our group, which means our Aro Group companies for accounting, statistical and analytical purposes. Aro Group consists of Aro & Aro 365 Mortgage Solutions. Aro Mortgages and Mortgage Advice Bureau are trading names of Aro 365 Mortgage Solutions Limited, who are Appointed Representatives of Mortgage Advice Bureau Limited.

Selected third parties. We may also share your information with selected third parties including:

• Credit Reference Agencies (“CRAs”): if you use our Services we will obtain on your behalf, in accordance with our Terms and Conditions, copies of your credit report and credit score from designated CRAs. In order to provide these services to you, we will share your information with such CRAs. The information which we provide to the CRAs may be supplied by them to other organisations such as Fraud Prevention Agencies and used by those organisations for the purposes of checking identity, preventing fraud, tracing and collection of debt. The CRAs may also use the data to undertake statistical analysis. If you choose to apply for a product, the lender will undertake a full credit check and provide you with further privacy information for that product.
• TransUnion  – Under data protection laws we are permitted to share some information where the reason for doing so is legitimate and isn’t outweighed by the effects it will have on the relevant individuals. On that basis we may pass your data to TransUnion (https://www.callcredit.co.uk/legal-information/bureau-privacy-notice) who may combine it with data from other sources, analyse and profile it (such as by predicting information about you), and pass their knowledge on to other companies to help trace you to provide important information or return assets to you. Your data may also be used in a similar manner to aid debt recovery and to prevent fraud by helping to identify you (for instance when you are applying for new products). TransUnion may also provide your data to other organisations to support the assessment of credit risk, pricing and affordable payments. If you do not wish for your data to be used this way by TransUnion then please contact us at compliancehelpdesk@aro.co.uk
• FCA regulated lenders (for example, to source and submit an application for loans, credit cards or mortgage products).
• Other credit brokers (if we are unable to service your request for a loan, credit card, or mortgage product).
• Debt-solutions providers such as Insolvency Practitioners (if you choose to take-advantage of our debt-advisory process).
• Solicitors & Surveyors (for example, to check the progress of your application with whom you are interacting).
• External suppliers – We may also share information with external supplier’s specialist IT system providers to facilitate the sourcing of products, to provide continuing advice, to inform you about relevant products and services, and to request feedback on customer service standards and to store data. It may also be necessary to share your personal information with non-affiliated companies who perform support services on our behalf including those that provide professional, legal or accounting advice to Aro Ltd.
• Other Credit Reference Agencies - From time to time we may pass your details to Trans Union or HD Decisions (an Experian business), to check your eligibility and to match you against loan products. This information will be used to let you know your chance of successfully obtaining a loan. For further information about how your details will be used please see the rest of our Privacy Policy and HD’s own terms and conditions https://termsandconditions.hdd2.co.uk/aro
• myfreedom and Fusion Score: Third parties which enable us to provide you with the myfreedom Service such as consents.online (please see consents.online Privacy Policy here: https://consents.online/Privacy for more information), cloud back-up and server hosting providers, IT software and third parties that provide communication services.
• Analytics and search engine providers that assist us in the improvement and optimisation of our service. We may use third party advertising platform providers such as Google to serve advertisements to you. These third parties may use information about your visits to this and other websites in order to provide you with advertising about products and services that may be of interest to you.
• Regulators – Sharing of information may be necessary with the Regulators to fulfil our legal obligations as a regulated profession, for example with the Financial Conduct Authority or the Information Commissioner’s Office. Sharing of information to verify your identity and comply with Anti Money Laundering legislation, and otherwise co-operate with law enforcement, legal proceedings or regulatory authorities.
• Others – If a third party introduced you to Aro, we may pass some of your personal information back to that third party so they know whether or not you took out a mortgage, credit agreement, debt solutions product or other service through us.
• 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.
• Your data will be treated confidentially and these companies are required to ensure appropriate security measures are in place and maintain the confidentiality of your personal data, and to use your personal data only in the course of providing such services and in accordance with Aro Ltd instructions.
• If we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets or the buyer or seller’s advisers
• If we or part or all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; and
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our myfreedom Terms and other agreements; or to protect the rights, property, or safety of Aro  Limited, our customers, or others.

WHAT IS THE LEGAL BASIS FOR US USING THIS INFORMATION?

We make sure we have appropriate legal bases on which to collect, use and share data about you. If you have any questions about the lawful bases on which we collect and use your personal data, you can contact our Director of Risk & Compliance.

Our lawful bases may include consent (where you have given consent), performance of a contract (where processing is necessary for the performance of a contract with you (such as delivering our core services to you), compliance with our legal obligations and our own legitimate interests.

• Consent. We will always seek your consent to process certain types of information where we are legally required to do so. You have the right to withdraw or decline your consent at any time. We use consent to initially engage with you to discuss your requirements including to confirm in which form we may communicate with you and re-engage, for example, when an existing product nears expiry.
• Performance of a Contract. To process and deliver your application for a loan, to offer you a recommendation to manage any outstanding debts you have, to manage our relationship with you & improve our customer service such as customer reviews / surveys. We need you to give us the information you provide, and to collect information about you from the Credit Reference Agencies and your Account Providers, in order for us to provide you with our services as agreed in our contract with you. If you do not give us this information, we will not be able to provide our services to you.
• Compliance with our legal obligations, to respond to enquiries and complaints, for example.
• Legitimate Interests. We may process your personal data for the purposes of our own legitimate interests or for the legitimate interests of our suppliers provided that such processing does not outweigh your interests. As an example, we may process your personal data to:
  • Comply with our legal obligations;
  • Keep our records up to date;
  • Provide you with our services, including for the purpose of quality control and analysis;
  • Develop and improve our products and services;
  • Communicating and managing our relationship with you;
  • Deliver relevant website and advertisement content to you;
  • Administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  • Measure or understand the effectiveness of the advertising we serve to you
  • Use data analytics to improve our website, products/services, marketing, customer relationships and experiences.

When we rely on our legitimate interests for processing your data, you have the right to object at any time.

HOW LONG WE KEEP YOUR INFORMATION FOR

How long we keep your information will depend on the purpose for which we use it, our obligations and your actions. We will only retain your information in an un-anonymised format for as long as is necessary for those purposes.

Where we receive your bank account information from Account Providers, we will retain it in the following manner:

• If you actively opt to revoke your consent we will immediately erase all your bank account information
• If you continue to have a myfreedom account we will retain your bank information for no more than 7 years from the date of the original consent

We will keep your personal information for as long as you are a user of the myfreedom Service. We may keep your personal information for up to 7 years after it is no longer required to provide you with the myfreedom Service. We do this:

• To enable us to respond to a question or complaint or to demonstrate we gave you fair treatment
• To study data as part of our own internal research;
• To obey rules that apply to us about record keeping.

We may also keep your data for longer than 7 years if we cannot delete it for legal, regulatory or technical reasons.

After termination of your account, we may continue to use anonymised data (which does not identify individual users) which is aggregated with anonymised data of other customers. We use this aggregated anonymised data for data analysis, profiling and research purposes, for example to gain insights about our users. We may also keep your email address to ensure that you no longer receive any communications from us.

WHERE DO WE STORE AND PROCESS YOUR PERSONAL DATA

We are committed to safeguarding your information and use industry standard methods to ensure that all the information you provide is secure. We store this on secure servers so that it can only be viewed by authorised personnel. We will only collect personally identifiable information to the extent deemed reasonably necessary to serve our legitimate business purposes. If we do transfer it outside the EEA, the information may be processed by staff operating outside the EEA who work for us or one or more suppliers. Such staff may be engaged in, among other things, the fulfilment of services, the processing of the application details, and the provision of support services.

HOW WE PROTECT YOUR INFORMATION

All information you provide to us is stored on our secure servers.

We do our best to protect your personal data, but we cannot guarantee the security of your data transmitted to our app; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access, loss or damage.

We only process your information within the UK and European Economic Area (EEA).

HOW LONG IS PERSONAL DATA RETAINED?

We only retain your personal data for as long as necessary, i.e. for our regulatory requirements or our legal obligation. The table below outlines how long data is retained, and depends on the reason the personal data is used for.

After these retention periods, if there is no other on-going relationship, your personal data will either be securely deleted or anonymised so that it can be used for statistical purposes but without any method of identifying you individually.

HOW MYFREEDOM USES YOUR DATA

The Fusion Score

The Fusion Score uses Open Banking to provide you with a complete view of your eligibility for credit. It does this by aggregating your Equifax Credit Report with insights from your bank transactions. For example: the money you have coming in each month, the money you typically have left each month, and how much you pay towards your rent, subscriptions and bills.  As a result, you can better understand your financial situation.

We do this as a result of our partnership with Consents.online Limited who are authorised by the Financial Conduct Authority as an Account Information Service Provider to provide Open Banking services.

Open Banking is a UK initiative to give regulated third party providers such as Consents.online access to consumers' financial accounts providing a consumer has given explicit consent for this to happen. Consents.online has appointed Aro as its agent and Aro has had this status approved by the Financial Conduct Authority: https://register.fca.org.uk/s/firm?id=0014G00002VoZzEQAV

We will share the personal information you have provided us with Consents.online and transfer you to its website. Consents.online is a separate data controller when it receives this information and will use it after obtaining your explicit consent so that it can access your bank account(s). Consents.online will provide you with a copy of its privacy policy which will explain clearly how you can do this.

• Your bank/building society will then verify your identity so that they can be certain you have securely shared your information with Consents.online and authorised it to have access to your account.
• Once this verification is complete, your bank/building society will provide Consents.online with 12 months’ history of your banking transactions. Consents.online will share this with Aro.

Aro use the information provided to us via Consents.online in the following ways:

• To calculate your Fusion Score. To do this, we use the categorised transactional information to analyse your income and expenditure. This enables us to: calculate what you can afford to borrow, exactly as a lender would. To grant you credit a lender is required by law to perform an ‘affordability check’ to work out how much money you could have left over at the end of each month if you were to borrow from them. Unlike a credit score your Fusion Score covers affordability as well as your credit history, which we get from your Equifax credit report.  
• To generate your positive and negative factors. This provides you with positive, neutral, and negative factors which are based on both the data we receive from Consents.online and Equifax.
• To pre-populate an application form you may elect to complete whilst using our service.
• To ‘enhance your offers’ during an eligibility search for a credit product. Some of our partners have products, special rates or pre-approvals that are only available to customers who share their bank transaction data with them when requesting a quote. Examples of Lenders who we might encrypt and onward-share your data with for this purpose are:
  • Lendable
  • My Community Finance
  • Oakbrook Ltd
  • Zopa
  • Leap Lending
  • Koyo
  • Capital One

Service Messages

The following communications are essential parts of delivering your myfreedom account and cannot be opted-out of:

• To send you a welcome email when you first create your account
• To notify you that you are yet to connect your bank
• We will email you reminders that your myfreedom account remains open no more than once every 90 days
• We will email you a copy of the results from any searches you may complete from your myfreedom account and reminders of when quotes expire

YOUR RIGHTS

You can exercise specific rights with regards to the data that we hold about you.

We will provide you with the necessary tools and contact details to be able to exercise your statutory rights regarding the information that we hold about you. You will be able to:

• Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. You have the right to request copies of all records we hold about you.
• Request correction of the personal data. This enables you to have any incomplete or inaccurate data corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete personal data where there is no reason for us continuing to process it or where you have successfully objected to the processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please note that we may not always be able to delete the data for specific legal reasons, if applicable we will notify you, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

For the exercise of any of your rights, you can also contact us at: compliance@freedom-finance.com

CHANGES WE MAKE TO OUR PRIVACY POLICY

We keep our Privacy Notice under regular review and may change it without notice.

Any changes we may make to our myfreedom Privacy Policy in the future will be posted on this page and, where the changes are material or we decide it is appropriate, notified to you by email. Please check back frequently to see any updates or changes.

Please also refer to our Terms & Conditions which outlines the service we provide.

MARKETING COMMUNICATIONS

You will also have the choice to opt-in to receiving other related marketing information and related products and services. Both we and other carefully selected organisations or alternative credit and insurance providers may contact you by telephone, letter, e-mail, SMS or other social media to offer other credit or insurance products which may be of interest to you. We may also send you information about money saving tips and guides. You can opt-out of receiving these types of communications at any time by contacting us at compliancehelpdesk@aro.co.uk or by clicking on the relevant link in email communications you receive from us.

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. We also limit access to your personal data to only those Aro staff, appointed representatives, advisers, business partners and suppliers 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.

COOKIE POLICY

Cookies are small text files placed on your device to store data when you browse a website. Cookies and similar technologies have several functions:

• storing your preferences and settings, which can be recalled when you re-visit a website
• delivering interactive services and completing applications
• maintaining online security and helping to protect against online fraud
• analysing how our products perform, tracking website performance, conducting research and diagnostics, and fulfilling other legitimate purposes to give you a better online experience
• storing and sharing your browser activity so that our advertising partners may provide content on products relevant to your interests
• helping us to understand how people use our website - for example, if lots of people give up on an application process at a particular step, we can try to make that step easier to use

* Please note that our cookies do not store any personal or confidential information about you

You can use controls in your browser to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking cookies. For more information, go to the Help section of your browser and search for 'cookies'.

Be aware that if you choose to disable or delete cookies relating to our website, the following may occur:

• we will not be able to recall information about you, including your preferences, and you will be treated as a first-time visitor
•  some of our online services might not work as you may expect
• as you browse from page to page relevant information may have to be entered more than once

To find out more about cookies, visit www.allaboutcookies.org. 

THIRD PARTY’S COOKIES

Cookies served by Equifax are held on Aro’s website. Equifax is a consumer credit reporting agency. These cookies will be used to serve adverts to visitors based upon the websites they’ve been to previously.

 Click here for more information about Equifax and how to disable this cookie.

WEBSITE LINKS

Aro Ltd 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 statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

If you follow a link to or from our app to a third-party website, please be aware that these websites have their own privacy policies.

Our Service may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.

Please also refer to our Terms & Conditions for more information

CONTACT US

If you have any questions or complaints relating to how we use your personal data, or if you wish to exercise any of your rights regarding your personal data, you may request this by writing to the Compliance Department Aro Ltd, Atlantic House, Atlas Business Park, Simonsway, Manchester, M22 5PR or emailing compliancehelpdesk@aro.co.uk

We shall respond to your request as soon as possible, depending on the complexity of the request but no later than one month from receiving it. If we need additional time, we will tell you and give you the reasons why.

If you are not satisfied with how we respond to your enquiry, you have the right to complain to the Information Commissioner’s Office (ICO), who is the regulator for data protection in the United Kingdom.

You may also have the right to refer any complaint you make to the Financial Ombudsman Service (FOS), which is an independent arbitration service and helps settle disputes between customers and businesses.

YOUR RIGHT TO LODGE A COMPLAINT WITH THE ICO

If you are not satisfied with our response to any complaints you raise with us or you believe our processing of your information does not comply with the data protection law, we suggest you contact us in the first instance. However, you can make a complaint to the Information Commissioner’s Office (ICO) at any time.

Please see the ICO website for further information – https://ico.org.uk/make-a-complaint/

Terms & Conditions

Our Terms & Conditions outline the services we provide. Please ensure you take time to read it carefully and if there is anything in this document that you are unsure about, please do not hesitate to contact us.

ABOUT US

Aro is a trading style of Aro Ltd. We carry out consumer credit brokerage, mortgage intermediation, credit information services, and we offer advice on debt solutions.

We are authorised and regulated by the Financial Conduct Authority and our Firm Registration Number is 662079. You can check this by visiting the FCA Register [HERE].

We comply with Data Protection laws in the United Kingdom and the EU General Data Protection Regulation (GDPR). Our ICO register number is Z120757X.

We are registered in England and Wales, company number 06297533. Our registered office is Aro Ltd, Atlantic House, Atlas Business Park, Simonsway, Manchester, M22 5PR.

SERVICES WE OFFER

We offer a range of unsecured personal loans and credit cards from a panel of lenders so you can make an informed choice. A list of the lenders on our panel is available on request. We do not provide advice on any unsecured credit products.

We offer full advice and recommendation on a range of second charge mortgages from a panel of lenders (a list of the lenders we have access to is available on request). This means we will:

• Complete a fact find and affordability assessment with you in order to understand your needs, preferences and circumstances.
• Learn about your lifestyle and financial expectations over the life of the mortgage.
• Explain the implications of the recommended mortgage features, both now, in the future and with interest rate movement.
• Explain the costs associated with the mortgage and the impact of adding any of these to the mortgage.
• Discuss the next steps and timescales including any administration / underwriting needed.

We offer advice on a range of debt solutions which you may be eligible for if you are struggling to repay your creditors. This means we will:

• Gather personal information about you, with your consent, covering your personal circumstances and income and expenditure.
• Display the advantages and disadvantages of debt solution(s) we think may be suitable for you, based on the information you have given us.

Offer you a referral to a debt solutions provider if we believe this may be in your best interests. The debt solutions provider will also offer you advice on how you can best manage your debt.

FEES & COMMISSION

For unsecured loans and credit cards, we do not charge you a fee for referral to a lender. Our income is derived from commissions paid by the lenders and other third parties we deal with for any successful introduction we make.

For second charge mortgages we may charge you a fee, actual fees and charges will be explained by the adviser prior to application & submission to a lender. We may also receive commission paid by the Lenders.

There may be additional costs relating to the mortgage we recommend to you and these will be detailed in the Mortgage illustration which we will send to you. A list of commission rates payable by the lenders is available on request.

For debt solutions, we do not charge a fee for any advice we give you. Our income is derived from a commission we may receive from a debt solutions provider we refer you to.

CREDIT CHECK AND DISCLOSURE

In order to process your loan or mortgage application, we may search the files of licensed credit reference agencies, who will keep a record of the search, to confirm your particulars and for the purpose of a credit assessment. A record can be kept of such searches which may be used by other lenders in assessing future applications for finance by you and for fraud prevention. These organisations may use this information in the future to help make credit decisions, prevent financial crime and to trace debtors.

Information held about applicants by credit reference agencies may already be linked to records related to one or more of your partners or members of your household. For the purpose of this application you may be treated as financially linked and the application may be assessed with reference to any ‘associated’ records.

We may also, as part of the application request a Lender’s Decision in Principle. This would involve the Lender conducting either a soft or hard credit search on all applicants, which may leave a mark on your credit files and can have a negative impact on your overall credit scores.

It is important that the information you provide is both accurate and honest, and a true reflection of your circumstances. It is your responsibility to provide information in this way to a provider or organisation that provides products and services recommended for you. Failure to disclose relevant information, or change of circumstances, to a provider or Lender may result in your product being invalidated.

If false or inaccurate information is provided, or if a reasonable suspicion of fraud or any other criminal offence is identified, details will be shared with fraud prevention agencies, law enforcement agencies and regulatory bodies who may access and use this information. We and other organisations may access and use the information recorded by fraud prevention agencies 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 of job applicants and employees

Details of the fraud prevention agencies we work with are available on request.

All transactions relating to our services provided are covered by, and adhere to, the Money Laundering regulations and the Proceeds of Crime Act. Our responsibilities include, but are not limited to, verifying the identity and address of our customers. Identity verification checks may include electronic searches through the Electronic Identification Verification Service, electoral roll and use of credit reference agencies.

We may also require proof of your income and expenditure to satisfy these requirements.

CREDIT REFERENCE AGENCY

Under data protection laws we are permitted to share some information where the reason for doing so is legitimate and isn’t outweighed by the effects it will have on the relevant individuals. On that basis we may pass your data to TransUnion (https://www.callcredit.co.uk/legal-information/bureau-privacy-notice) who may combine it with data from other sources, analyse and profile it (such as by predicting information about you), and pass their knowledge on to other companies to help trace you to provide important information or return assets to you. Your data may also be used in a similar manner to aid debt recovery and to prevent fraud by helping to identify you (for instance when you are applying for new products).

TransUnion may also provide your data to other organisations to support the assessment of credit risk, pricing and affordable payments. If you do not wish for your data to be used this way by TransUnion then please contact us at compliancehelpdesk@aro.co.uk.

ACCURACY OF LOAN QUOTE

Aro Ltd takes every care to ensure the accuracy of the loan quotes which are based on the latest information available from the lenders at that time. However, the lenders on the panel reserve the right to change % APR or % APRC rates and underwriting criteria at any time and without notice. This may result in a change to the loan/secured loan offered to you or may result in the loan/secured loans offer being withdrawn.

The accuracy of the loan/secured loan quotes depends upon the accuracy of the information you have provided. Aro Ltd and the lenders on the panel will conduct checks to verify the accuracy of the information you have provided. If information you have provided changes as a result of these checks, the original offer may be changed or withdraw.

The expected time periods from submitting your application to receiving your loan/secured loan funds are only a guide. Any delay in the returning of your loan documents, proof of income or identification and/or delays with any third party we or the lender need to contact in order to process your application, may result in your application taking longer to complete.

If you’re thinking of consolidating existing borrowing you should be aware that although you may reduce your monthly outgoings you may be extending the terms of the debt and increasing the total amount you repay.

It's important that you can afford the repayments now and continue to do so throughout the term of the loan as failure to keep up with your repayments could lead to defaults, CCJ's, ultimately bankruptcy and affect your ability to obtain future credit.

If you use our service to receive advice on debt solutions available to you, we will present potential solutions based on our understanding of the debt products available at that time. The validity of the solutions we present to you will depend on the accuracy of the information we hold about you and therefore you should make sure any information you give us is accurate and complete.  

DEBT ADVICE

We offer advice on the full range of debt solutions which you may be eligible for if you are struggling to repay your creditors. This is via an online solution we have developed which uses information about your income and expenditure and current indebtedness in order to offer you recommendations on a possible course of action.  

We will:

• Gather personal information about you, with your consent, covering your personal circumstances and income and expenditure. We use an Open Banking solution for this, or you can input your details manually. Please make sure the details we have about you are complete and accurate to the best of your knowledge as this may impact the recommendation we are able to offer you.
• Display the advantages and disadvantages of debt solution(s) we think may be suitable for you, based on the information you have given us.
• Offer you a referral to a debt solutions provider if we believe this may be in your best interests.
• The debt advisor you deal with will make clear which of your debts are or are not included in the debt repayment solution. If you leave any debts out of the solution, then these will not be repaid by the plan you enter into which means you will still owe those debts.
• Not charge you a fee for our service. However, you will be charged a fee if you enter into a debt solutions product through one of our partners.

We don’t recommend a particular debt solution and we don’t settle any debts for you, but we do introduce you to debt solutions providers who can help with this. The debt solutions provider will then offer you advice on how you can best manage your debt.

If we have referred you to a commercial debt management provider, then they will make a charge for their services and pay Aro a commission if you take out a debt-solutions product. You should be aware that there are organisations which provide debt advice free of charge and you can find out more from Money Advice Service, Step Change, or the Citizens Advice Bureau.

THINGS TO KNOW ABOUT DEBT SOLUTIONS

There are important thigs to remember when exploring your options for debt repayment:

• If you use one of the options we recommend for managing your debts, then your credit rating may be affected for up to six years.    
• Keep making payments until you have agreed otherwise with your creditors. This means you should carry on paying things like your credit, taxes, child support arrangements etc. If you don’t do this, your credit rating could be impacted and enforcement action could be progressed against you.
• Never ignore letters or phone calls from people you owe money to. Doing so could make your situation worse.
• Entering into a debt solutions arrangement may not guarantee that any current recovery or legal action against you will stop.
• If you don’t keep up with any repayment arrangement you enter into, there could be negative consequences which may even include bankruptcy.

​​​​​HOW TO GIVE FEEDBACK OR MAKE A COMPLAINT

Your opinion is very important to us. Listening to your views helps us develop our company ethos of having customers at the heart of what we do. Please e-mail support@aro.co.uk with any feedback you may have.

We all make mistakes and if we do get something wrong we want to know about it so we can put it right. We treat all complaints very seriously and promise to deal with them fairly and promptly, and in many cases we will resolve them straight away.

If you have a complaint please contact us by writing to the Complaints Department at the above address, via e-mail to complaints@aro.co.uk or telephone us on 0161 498 7739.

Aro Ltd will try to resolve any complaint with you. However if you are unhappy with our final response or we are unable to issue our final response within 8 weeks of receiving your complaint you can refer your complaint to the Financial Ombudsman Service. You can get more information at: https://www.financial-ombudsman.org.uk/

We are covered by the FSCS. You may be entitled to compensation from the scheme if we cannot meet our obligations. This depends on the type of business and the circumstances of the claim.. You can get more information at: https://www.fscs.org.uk/

PRIVACY COMPLAINT

Aro Ltd is committed to keeping your information private. By your ‘information’ we mean any information about you or anyone associated with you that you or a third party provides to us, as a result of the application process. If your complaint is related to how your personal data has been processed and you are not satisfied with the response from us, you have the right to complain to the Information Commissioners Office (ICO) who is the regulator for data protection in the United Kingdom.

We have a separate ‘Client Privacy Notice’, setting out how we collect and process your information. This should be read in conjunction with our ‘Terms & Conditions’.

WHO WE MAY SHARE YOUR DATA WITH?

We may share your data with lenders or service providers who you ask us to provide an eligibility quotation. Occasionally we may share your data with other third parties, such as a lender you select, a debt management company or Insolvency Practitioner if you select that service, other service providers, Credit Reference Agencies and Fraud Prevention Agencies.

We may need to disclose your data to others to ensure the smooth provision to you of our Services and any information you request. Your data may be disclosed to the other entities as described below.

Sub-processors. We may share your information with the following sub-processors:

• Equifax (Credit Reference Agency)
• Experian (Credit Reference Agency)
• consents.online (Account Information Services Provider)
• Aryza UK Services Limited (provider of the software we use to provide advice on clearing your debts)

• Capital One plc (credit card eligibility checker and provider). For further information on how Capital One plc use your data, view their Terms and Conditions: https://www.capitalone.co.uk/creditcards/quickcheck-terms-conditions.jsf 

TERMS OF WEBSITE USE

Your use of this website constitutes your agreement to all the terms of use detailed below. The information that is made available on this website is intended for general information purposes only and is provided on an ‘as is’ basis without any warranties of any kind. Aro Ltd does not accept any liability for any loss arising as a result of reliance on the information contained on this website.

This website is owned by Aro Ltd and is protected by copyright and database rights. You acknowledge that all trademarks (registered or unregistered) used in providing this service shall remain the property of Aro Ltd at all times.

You shall not copy, adapt, exploit or otherwise use the information contained on this website in any way, save for the downloading and temporary storage of one or more of these pages for the purpose of viewing on a personal computer or terminal, provided that you do not delete any copyright and other proprietary notices contained therein.

We may make improvements or changes to the products, services and prices detailed on this website at any time without notice.

If you choose to use such a link as detailed in ‘How we use third party websites’ then you will leave this website. Once you leave this website, whether or not you realise that you are leaving, we are no longer in any way responsible for the material on the other website that you enter. We exclude to the fullest extent permitted by law all liability that may arise in connection with or as a result of such external website material causing any damage, costs, injury of financial loss of any kind.

You agree that you will not use this website to: a) Commit or encourage any criminal offence, including but not limited to harming a minor in any way and stalking or harassing another; b) Insert or knowingly or recklessly transmit or distribute a virus, worm, trojan horse, time bomb, trap door or any other computer code, files or programs or repetitive requests designed to interrupt, destroy or limit the functionality of any computer software or hardware or telecommunications equipment or to diminish the quality of, interfere with the performance of or impair the functionality of this website; including carrying out any hacking activity; c) Circumvent, or attempt to seek to circumvent, any of the security safeguards of this website; d) Permit any third party to do any of the above.

While we try and ensure that all information on this website is accurate and up to date, errors may occur and we accept no liability for such errors. If we discover an error we will amend the website as soon as reasonably possible.

We neither warrant nor represent that your use of this website will not infringe the rights of third parties.

We are interested in protecting your personal information and we only use your personal information in accordance with our Data Protection Policy.

You have sole responsibility for adequate protection and backup of data and/or equipment used by you in connection with this website and will not make a claim against Aro Ltd for lost data, re-run time, inaccurate output, work delays or lost profits resulting from the use of such materials.

We may edit this policy from time to time. If we make any substantial changes we will notify you by posting a prominent announcement on our pages.

Aro Ltd reserves the right to refuse access to this website or any component of it. We may at any time, at the discretion of the site’s management, refuse access to certain areas of this website to any individual it chooses – this refusal of access may take whatever form the management deem suitable.

This site is controlled and operated by Aro Ltd from the United Kingdom. Aro Ltd makes no representations that materials in this website are appropriate or available for use in other locations. Those who choose to access this website from other locations do so at their own risk and are responsible for compliance with any and all local laws, if and to the extent local laws are applicable. No material from this website may be downloaded, exported or re-exported into (or to a national or resident of) any countries that are subject to UK exporting restrictions/legal or socio-economic sanctions.

COOKIE POLICY

Cookies are small text files placed on your device to store data when you browse a website. Cookies and similar technologies have several functions:

• storing your preferences and settings, which can be recalled when you re-visit a website
• delivering interactive services and completing applications
• maintaining online security and helping to protect against online fraud
• analysing how our products perform, tracking website performance, conducting research and diagnostics, and fulfilling other legitimate purposes to give you a better online experience
• storing and sharing your browser activity so that our advertising partners may provide content on products relevant to your interests
• helping us to understand how people use our website - for example, if lots of people give up on an application process at a particular step, we can try to make that step easier to use

* Please note that our cookies do not store any personal or confidential information about you.

You can use controls in your browser to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking cookies. For more information, go to the Help section of your browser and search for 'cookies'.

Be aware that if you choose to disable or delete cookies relating to our website, the following may occur:

• we will not be able to recall information about you, including your preferences, and you will be treated as a first-time visitor
• some of our online services might not work as you may expect
• as you browse from page to page relevant information may have to be entered more than once

To find out more about cookies, visit www.allaboutcookies.org.

LAW AND JURISDICTION

All the credit and mortgage products we intermediate are governed and construed in accordance with the laws of England and Wales, in relation to any dispute. For your protection you agree to submit to the non-exclusive jurisdiction of the English courts.

Any debt solution product we intermediate may be governed by the laws of England and Wales, or the laws of Scotland, dependent on where you live. This will be clarified by the debt solutions provider prior to you taking out a solution with them.

FURTHER INFORMATION

We may edit this policy from time to time.

If you have any questions about these Terms and Conditions, or any other aspect of our website please write to us at; Aro Ltd, Atlantic House, Atlas Business Park, Simonsway, Manchester, M22 5PR or telephone us on 0161 498 7739 (calls may be recorded for training and monitoring purposes) or email us at support@aro.co.uk.