Zopa Privacy Notice
This is the Privacy Notice for Zopa Bank Limited referred to as “Zopa”, “we”, “us” or “our” in this document.
This Privacy Notice provides details of what information we collect from you, what we do with it, who we share it with and your rights in relation to it.
Last updated: April 2023
1. The information we collect about you
The types of personal data that we collect and process about you will depend on how you interact with Zopa and what Zopa products, if any, you use.
It may fall into the following categories but will extend to any data about you that we process as a result of your interactions with Zopa.
We may also collect ‘special category data’ about you. As this is treated differently under data protection law, there’s a section dedicated to it below.
|Personal Data||Uses of your information|
|Contact and ID||
|Marketing and advertising||
This information may come from:
- You, when you want to apply for any of our products e.g. if you apply for a loan (including if your application is declined) or ask us to provide you with a personalised rate
- The way you use your account, and our website, app and online services
- Your other interactions with us, including information you share with us
- Credit reference agencies (who may check the information against other databases – public and private – to which they have access), fraud prevention agencies or third parties that help us to prevent fraud and meet our legal obligations
- Your financial services providers
- Our open banking providers
- Retailers that offer our point of sale product (both where you’re interested in taking out point of sale finance, and have taken it out)
- Any company in the Zopa group (see “Group companies” below for more information)
- Other third parties and other publicly available sources, e.g. we may buy or rent marketing lists from third parties, which contain the contact details of individuals (including you) to whom we can send marketing materials. This may extend to adtech networks where we want to show people adverts for Zopa.
- 2. Using your information
Data protection law requires us to have a legal ground to use your personal data. We rely on one or more of the following grounds to use your personal data:
- To perform our contractual obligations under our agreement with you;
- To comply with a law that we are subject to as a financial institution;
- We have a legitimate interest in using your information which isn’t outweighed by your interests, rights and freedoms;
- You have given us your consent.
We’ve set out in the table below how we use your personal data and the legal basis for using it. We also cover ‘special category data’ in more detail below:
|How we may use your information||Lawful basis for processing|
|To onboard and serve you as a customer:
||To perform our contractual obligations under our agreement with you:
|To improve our business and products:
|To protect our business:
|To comply with laws and regulations:
||To comply with laws and regulations:
|To provide an enhanced service:
|To display advertising to you across the web and on social media platforms
We will process your data so that we can show you adverts for Zopa, including through providing personal data to Facebook and other social media platforms. We may do this as a result of you visiting Zopa’s website or if we think you might be interested in seeing these ads. See “Advertising” below for more details.
|You have given us your consent
|Third Party Marketing:
||You have given us your consent.|
When you register with Zopa we’ll give you the option to opt-out of receiving different categories of messages from us. These categories relate to letting you know about new products or launches, promoting our existing products, and asking for feedback. Messages we send can include marketing about Zopa products and also any products our group companies offer, including under the trading name DivideBuy (see ‘Group companies’ below for more information’).
We only send these messages if there is something worthwhile to tell you about. If you don’t want to receive these messages you can log into your account and change your settings.
We’ll still send your messages relating to Zopa products you have where this is necessary to provide you with a good service. There also may be some messages that we’re required by law or regulation to send you even if you ask us not to.
Special category data
Data protection law requires us to treat special category data with more care. Special category data includes biometric data (physical, physiological or behavioural characteristics about you), health data, criminal convictions, and any religious or political data.
We’ll only use special category data for the following purposes:
- detecting and preventing financial crime,
- verifying your identity through the use of biometric data; and
- making our services accessible to customers.
Also we’ll only process special categories of information where we’ve obtained your explicit consent or where one of the limited grounds on which we can process special category data applies.
- 3. Sharing your information
We use and work with a range of third parties as part of running our business. This means that we may have to share your information with them and they may have to share your information with us. These third parties include:
- Credit reference and fraud prevention agencies
- Our regulators or government authorities, for example the Financial Conduct Authority, the Financial Ombudsman Service and the police
- Collection agencies and lawyers to help us collect any money you owe us
- Third party service providers that help us provide services to you including cloud based service providers, payment processors, and third parties that help us communicate with you (SMS, live chat, email). These service providers include “white label” service providers who use Zopa branding and operate as Zopa to help improve the customer journey. Our current white label service providers are:
- Evolution Funding Ltd, who contact our auto loan customers where they have chosen vehicles outside of a dealership in order to run vehicle and seller checks. Evolution Funding Ltd may also act as a finance broker for customers to check if other lenders are able to offer you finance, if we’re unable to help.
- Paylink Solutions, who provide a budgeting tool that customers can use when they have loan repayment issues.
- Decision Tech, who provides an energy comparison and switching service in our app
- Motiv Finance, who provide prospective auto loan customers with a catalogue of vehicles available for purchase.
- Companies that help us understand, improve and market our products, and also that help us prevent fraud and criminal activity.
- Retailers that you’ve purchased goods or services using loans provided by us
- Financial services providers to facilitate open banking services (like giving you the ability to transfer funds from another bank account to a Zopa product within the Zopa app or to give us access to your transactions)
- If we are unable to offer you a loan, credit brokers or other lenders who may be able to arrange credit for you.
- If a borrower is unable to repay their loan, we may use the services of debt collection agencies and lawyers
- if someone else is appointed to handle your affairs (for example a trustee in bankruptcy or someone acting under a power of attorney)
- potential acquirers of Zopa or its assets including debt held by Zopa (as part of a sale of assets or shares, including as part of an insolvency)
- financial institutions who have received funds from you fraudulently (for example where you send funds to a bank at the direction of a fraudster).
- academic institutions, for example to help understand trends in lending
We make available transactional information (for example loan amount and repayment details) on an anonymised basis to the public. We will not be responsible for misuse of transactional data by others. You should inform us promptly if you are the victim of any misuse of that information so we can investigate any such matter and prevent further misuse immediately.
Third parties’ use of data for their own benefit
We use a range of third parties to provide services to us. Most of these third parties will process data only on our behalf to provide services to us.
However, some will make use of your data for their own purposes. Sometimes this is so they can comply with their own legal obligations, other times it’s to improve their own products and services or to troubleshoot issues.
Where data is used to benefit their own services, it will usually be on an anonymised and aggregated basis, meaning that once your data has been used, it will no longer be stored by the third party. One example of this is that third parties may use your personal data to improve their own models (used to assess risk or predict behaviour) by processing your personal data. Insights derived from your data will remain in the model but the underlying personal data will be anonymised/deleted.
We will never permit third parties to use your personal data to market to you in their own name unless we have your consent.
We use Twilio to send SMS messages to you to provide a more secure login experience. In addition to Twilio using data to provide services to Zopa, they also make use of data to for their own purposes, including billing, reconciling invoices with telecommunications carriers, and to troubleshoot and detect problems with the network. More information on Twilio’s practices can be found here: https://www.twilio.com/legal/privacy.
Open Banking is a catch-all term used to describe efforts to make it easier for financial services providers to talk to each other.
Using Open Banking, you can:
- transfer funds directly from a bank account you hold with another bank within the Zopa app
- give us access to financial transactions with your other financial service providers so we can give you a personalised view of the products and rates we may be able to offer you, provide you with tips and helpful information about your finances and the general economy.
If you use Open Banking features, we’ll transfer personal data about you to the other bank. In turn, they’ll transfer data about you back to Zopa. For example, if you want to transfer funds from your other bank to Zopa, we’ll transfer data about the request to your other bank, and your other bank will let us know whether the transfer has been approved by you.
We work with TrueLayer and Bud to help with this. They act as the glue between Zopa and other financial services providers. If you use any Open Banking features that Zopa make available, you’ll have to agree to separate terms and conditions made available by them.
If you withdraw your consent for us to access your Open Banking data, we won’t receive any further Open Banking data from your other financial services providers. However we will retain the Open Banking data we previously accessed before you withdrew your consent (see ‘Retaining your information’ below).
When you give us access to your Open Banking data, the records of your financial transactions that we receive may also include the personal data of other individuals, like the name of the person you have sent a payment to or received a payment from. If a third party whose data we have captured when accessing your financial transactions, requests we delete their personal data, we will seek to comply with this request.]
- 4. Tools
We make Tools available in the Zopa app which are generally designed to help you manage your finances. These Tools use your Open Banking data and/or credit file data toYou can access these Tools through our mobile app. Our Supplementary data and Tools terms provide additional information about the ways our Tools make use of your personal data.
- 5. Credit reference agencies
If you ask us to provide you with a personalised rate for one our products we’ll supply your personal data to credit reference agencies (CRAs) and carry out what’s called a ‘soft credit search’ to get a view of your credit rating.
The CRAs will record our search but other lenders won’t be able to see it and it won’t affect your credit score.
When we perform a soft search on you, this will also include a soft credit search of any person that you share financial ties with (a joint current account or a joint mortgage, for example), this person is known as a ‘financial associate’. Beyond using your financial associate’s data for decisioning purposes, we will not use their data for any other purpose.
However, it will leave a soft search on their credit file, so you should make them aware before requesting a quote.
CRAs link your records together and these links will remain on your and their files until such time as you or your partner successfully files a request with the CRAs to break that link.
The above soft search will give us an overall view of your financial health (including your credit score) but not your full credit report. This will help us determine whether your application is likely to be successful and the interest rate we might charge.
It’s only when you accept our offered quote that we will carry out a full search of your credit report. CRAs will supply to us both public (including electoral register) and credit, financial situation and financial history information and fraud prevention information about you.
We will use your credit file information to:
- Assess your creditworthiness and whether you can afford the product you want
- Verify the accuracy of the information you have provided us
- Prevent criminal activity, fraud and money laundering
- Manage your account
- Trace and recover debts
- Ensure any offers provided to you are appropriate to your circumstances
We’ll go on sharing your personal data with CRAs for as long as you are a customer. We will also inform CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. They may also provide this information to other organisations including financial institutions who offer similar products to Zopa.
As a general rule, we’ll give you at least 28 days’ notice if we decide to file a default on your credit reference file. However, we may not always give you notice beforehand, for example, if we plan to take court action.
As well as the above:
- we’ll get information from CRAs about changes in your circumstances that might affect your ability to repay us. This is to help us monitor your situation so we can take early action to help you manage your repayments to us. Information we get includes any recent bankruptcies or county court judgments, or any missed payments or significant changes in your debt (including with other lenders), together with scores created by the CRAs relating to your continuing ability to repay your borrowing.
- we may conduct searches with credit reference agencies to verify any identity and bank account details you provide to us (for example where you are linking a bank account to your savings account). As above this may result in a record of this check being added to your credit file.
- We may use data from credit reference agencies to supplement data you’ve provided to us for the purposes outlined below in “Automated Decision Making and Profiling” and to help us understand you better, generally, for example, whether you would be interested in other Zopa products.
The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal data, data retention periods and your data protection rights with the CRAs are explained in the Credit Reference Agency Information Notice (CRAIN), which is available from each of the three CRAs-clicking on any of these three links will take you to the CRAIN document:
- 6. Fraud prevention agencies
If you give us false or inaccurate information or if we suspect or identify fraud we may record this and may also pass this information to fraud prevention agencies and other organisations involved in crime and fraud prevention including law enforcement agencies.
We can also use any data you give to us or that we collect about you, including where we collect data from you to verify transactions, data obtained from credit reference agencies or from cookies or other online identifiers.
We and other organisations may access and use the above information to investigate and prevent fraud, money laundering or other criminal activity.
Fraud prevention agencies may hold your information for different periods of time, and if you’re considered to be a fraud or money laundering risk, your information may be held for up to six years. It may also result in us and others refusing to provide services, financing or employment to you.
You can contact us using the methods available at zopa.com/contact if you’d like to know more about the credit reference and fraud prevention agencies we use. The fraud prevention agency we currently use is Cifas. We use Cifas to help prevent fraud, money laundering and to verify your identity.
Further information about how Cifas process your data can be found on their Fair Processing Notice.
- 7. Overseas transfers
We may transfer your personal data to countries outside either the UK or the European Economic Area (EEA), whose personal data protection laws are less strict than in the UK or the EEA.
Where we do so, we will make sure suitable safeguards are in place to protect your personal data, in line with data protection law. The safeguards we use will depend on the circumstances and the third party who we transfer data to, but include the EU Commission’s standard contractual clauses.
Whenever fraud prevention and credit reference agencies transfer your information outside the UK or the EEA, they will also ensure the transfer takes place in accordance with data protection laws.
Please contact firstname.lastname@example.org if you want to know more details about the above safeguards or obtain a copy of the standard contractual clauses we use to transfer data outside the UK and the EEA.
- 8. Retaining your information
We will hold your information for as long as you have a relationship with us, (. you’ve applied to take out a product with us or you’re an existing customer with us), and for a period of time after our relationship has ended (we’ve declined your application, or you’ve closed your account).
How long we’ll keep your information for will depend on the nature of our relationship, the type of information and the purposes for which we hold it.
We’ll retain information that helps us to:
- comply with legal and regulatory requirements, e.g. anti-money laundering laws and laws that require us to keep details of transactions we’ve been a party to (loan repayments, investor payments)
- establish, exercise and defend legal claims
- prevent and detect fraud
- pursue our (or a third party’s) legitimate interests, e.g. developing and improving credit risk models to help us make better lending decisions. For example, where you are a Zopa borrower, we will retain your data for analysis and also provide it to credit reference agencies so they can also use it for the purposes outlined in this bullet point
- deal with any complaints regarding the services we’ve provided
- ensure we don’t send marketing to people who have opted out
- maintain business records for analysis and audit purposes
- 9. Automated decisions and profiling
We use automated decision-making and profiling to help our business and our customers, including by giving them decisions more quickly, detecting fraud, and helping us to understand our customers better.
Lending Decisions- When you apply for a product where Zopa will provide credit to you, we’ll use automated decision-making and profiling to decide whether to lend to you, i.e. we may make our decision without any human involvement. This helps us to make quicker lending decisions.
The process works by taking information you’ve provided when applying for the loan, any information we already have about you and information we obtain from third parties such as credit reference and fraud prevention agencies to calculate a credit score for you.
This information may include:
- your address history, your employment history, and the industry sector you work in
- bank account statements and open banking data (transactions, balances)
- Your account history with us
- The number and type of credit agreements you have and how you’ve used them
- Whether you’ve been late making payments
- Whether you’ve had any court judgments made against you or whether you’ve been made bankrupt or had an IVA or other form of debt-related arrangement.
Using an automated credit scoring process means we may automatically decide that we are unable to offer you a loan, or only offer you a loan for a lower amount and/or shorter term that you requested.
As part of our loan decisioning process, we use profiling to make better lending decisions. This works by grouping together applicants who share certain characteristics. This can help us understand the likelihood of whether someone will repay their loan (for example people in some types of jobs, may be more likely to repay their loan in full, compared to others).
Our credit scoring methods are regularly tested to ensure they remain fair, accurate and unbiased.
In addition to the original lending decision, if you’re an existing borrower and we think you may be interested in borrower additional sums, we’ll also use data about you to make an automatic decision on whether or not you’re eligible for additional lending.
We use automated processes to detect and help prevent fraud.
We may automatically decide that you pose a fraud or money laundering risk if our processing reveals your behaviour to be consistent with money laundering or known fraudulent activity, or is inconsistent with your previous submissions, or you appear to have deliberately hidden your true identity.
If we think there is a risk of fraud we may refuse to proceed with your application, suspend your account and/or refuse you access to it.
Developing and marketing our products and services and finding new customers
We may use automated decision-making and profiling to help us develop products and services that would be of interest to existing and prospective customers, to manage your existing products and services to help you get the best out of them, and to provide you with marketing messages that we think you’ll be interested in (for example, if you have one of our products, we might profile you to understand what other Zopa products we think you might be interested in). This automated-decision making and profiling may mean us making changes to your current products and services or the way we communicate with you.
As part of the above, we may provide your personal data to credit reference agencies to get more data about you to supplement our picture of you.
Your rights in relation to automated decision making
See “Your rights” below, for details about your rights in relation to automated decision making.
You can ask us to reconsider any declined decision by contacting us using the methods available at zopa.com/contact.
- 10. Advertising
Like most businesses, we use advertising to let people know about our services and products. Our use of advertising can involve the use of ad networks which enable potential advertisers to bid for the right to show advertising to you across the web. Part of this process involves the use of a range of data about you (location, gender, preferences and interests) to allow better targeting of adverts so you hopefully see adverts relevant to you. However it will mean that data about you is shared with a large number of third parties (ad network operators and potential bidders).
As a result, you may see adverts for Zopa across the web. This includes where you have visited our website (because we think that because you visited the Zopa website previously you may be interested in Zopa’s products).
If you see an advert for Zopa and also if you interact with the advert and come to Zopa’s website, we’ll also measure the effectiveness of adverts, including by seeing how long you spend on our site. We also use tools to help us attribute app installations to a particular marketing campaign so we can make better use of our advertising spend in future.
In addition to cookies and similar technologies used by Zopa as part of advertising to you across the internet, if you are an existing customer of Zopa, we may also send your contact details to social media sites. We do this so we can find out if you’re also a member of those sites and if so, advertise our products to you through those sites. For example, we use Facebook’s Custom Audiences for this purpose. When we provide contact details to Facebook, they will only use this data for the purpose of determining whether you’re on Facebook.
- 11. Consequences of processing
If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide you with the services or financing you have requested, or we may stop providing existing services to you.
A record of any fraud or money laundering risk may be retained by fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us using the details above.
- 12. Your rights
Right to be provided with certain information
We must provide you with certain information at the time we collect your personal information, including how we use it and the legal basis for doing so, who we share it with, how long we intend to keep it, where we got the information from and your rights in relation to it. You find this information in this Privacy Notice.
Right to withdraw your consent
Where we rely on your consent to use your personal data (for example with our Tools, or for the use of biometric data for verifying your identity), you can withdraw that consent at any time and we’ll stop any further processing of the data linked to your consent (we may retain the same data on a different legal basis however).
Right to access your information
You can ask for a copy of the personal data we hold about you (and other information relating to it) unless providing some or all of it would adversely affect the rights and freedoms of others, or the law requires us not to comply with your request. You can make a request to access your personal data by contacting us using the methods available at zopa.com/contact. We aim to provide you with your data within 30 days.
Right to correction
You can ask us to correct any personal data we hold about you which you believe is inaccurate. We’ll update your information as soon as we can. You may need to provide supporting evidence before we can deal with your request; e.g. a copy of your marriage certificate if you want to update your name.
Right to erasure (‘right to be forgotten’)
You can ask us to erase your personal data:
- if you think it’s no longer necessary for us to hold your information;
- if you don’t think we have any legitimate grounds for processing it;
- if you think we’re using your personal data unlawfully; or
if you think we should delete your personal data because the law requires us to do so.
Right to restrict processing
You can ask us to stop using your personal data:
- if you think it’s inaccurate
- if you think it’s illegal for us to use it
- if you don’t want us to destroy it because you need it for legal proceedings
- if you’ve told us we don’t have a legitimate reason for using it and we’re considering your request
You can ask us to notify everyone to whom we’ve given your personal data whenever we amend, delete or agree to restrict our use of it.
Right to data portability
If we’re using your information on the basis of your consent or because we need it to carry out our contractual obligations to you, you can ask us to give you your personal data in a structured, commonly used and machine-readable format or have it transmitted to another data controller.
Right to object
You have a right to object whenever we are using personal data on the basis of our legitimate interests (section 2 contains the ways in which we rely on legitimate interests to use your personal data). This includes where we use your personal data for direct marketing purposes, including profiling.
Right to human intervention
When you apply for a product involving credit we’ll use automated decision-making to decide whether to lend to you. If we decline your application, you can ask one of our underwriters to review our decision.
We may not always be able to comply with your requests
There may be occasions when you wish to exercise one of your rights and we’re unable to agree to your request, e.g. because we have compelling grounds for using your information, or because we need to keep your information to comply with a legal obligation.
Making requests to exercise your rights
You can send us your request by contacting us using the methods available at zopa.com/contact.
How to stop receiving marketing messages
If you no longer want to receive marketing messages you can log into your account and change your “Profile” settings. If you need help with this, please get in touch using the methods available at zopa.com/contact.
- 13. How to contact us or make a complaint
If you have any further questions about privacy at Zopa, or if you are unhappy with how we’ve handled your information you can contact us at:
The Data Protection Officer (DPO)
47-49 Tooley St
Or by email at: email@example.com If you are still unsatisfied you can refer your concerns to the Information Commissioner’s Office, the body that regulates the handling of personal data in the UK, at:
Information Commissioner’s Office
- 14. Consequences of not providing us with your personal data
You don’t have to provide us with your personal data. However, we need your information partly because the law requires us to ask for certain details about you (for example, so we can verify your identify) and partly so that we can provide products and services to you.
This means that if you don’t provide us with the information we ask for, we’ll not be able to open an account for you.
- 15. Keeping your data safe
We take your privacy seriously and take every reasonable measure to keep your information secure. We monitor our systems 24/7 and continually work to improve the security of your personal data and our systems.
- 16. Cookies
- 17. About Zopa
Zopa Bank Limited is a company incorporated in England & Wales under company registration number 10627575. Our registered office at 1st Floor, Cottons Centre, 47-49 Tooley Street, London SE1 2QG. We’re registered with the Information Commissioner with registration number Z879078. We’re also authorised and regulated by the Financial Conduct Authority and entered on the Financial Services Register under firm registration number 800542.
- 18. Group companies
Companies in the Zopa group work closely together and frequently support each other’s operations. As a result, we may share your personal data between any group companies in the Zopa group. Examples of this include for marketing purposes, and where one group company provides services to another.
As well as the main company in the group is Zopa Bank, Zopa Embedded Finance Limited (ZEF) also sits in the Zopa group. In April 2023, ZEF acquired the assets of a point of sale business (where you can get finance for purchases with merchants at the point you buy something) called DivideBuy. As a result, ZEF offers point of sale finance under the trading name DivideBuy.
- 19. Changes to this Privacy Notice
We’ll regularly review this Privacy Notice. If we make any changes, we’ll post the updated policy on this page.
[ ] April 2023 Provided more information about Zopa group companies following the acquisition of the DivideBuy business
2 March 2023 Provided more information about open banking
22 June 2022 Updated to reflect wind-down of the peer to peer business
12 April 2022 Provided more detail about how your data is used when you use Open Banking features
26 March 2021 Provided more detail on a new white label provider and a few additional areas where we provide data to third parties
26 June 2020 Provided more detail on the use of profiling in credit risk analysis, white label providers used by Zopa, and ongoing monitoring of people we lend to.
11 March 2020 Provided more detail about the third parties that we can disclose data to, more information into how data about financial associates is dealt with, and special category data.
12 November 2019 Provided more detail on use of data in relation to online advertising and the third parties we can disclose your data to.
21 August 2019 Provided more detail about Zopa’s fraud prevention measures, including our use of Cifas. Additional cosmetic changes following an internal review.
4 December 2018 We extended the policy to cover Zopa Financial Services Limited, which will launch as a bank next year.
1 December 2018 We added details of how our company is now structured and regulated now that we have a banking licence.
23 November 2018 Added contact details for our Data Protection Officer (DPO).