1. Who Are We?
Tomorrow Loans PLC (company number 11815008) (â€œTLâ€) is a company incorporated in England & Wales. Our registered office address is 2 Old Bath Road, Newbury RG14 1QL, UK. This policy applies to our collection and use of your data in connection with your use of our website (the â€œWebsite Useâ€). We are registered with the information Commissionerâ€™s Office as a data controller.
2. How to Reach Our Data Protection Officer?
To contact TLâ€™s Data Protection Officer regarding our processing of your personal data, email firstname.lastname@example.org.
3. How Do We Notify You of Changes to this Policy?
4. What Are Your Rights?
TL recognises that your personal data belongs to you and we donâ€™t wish to use it in ways that you donâ€™t want us to.
You can control whether or not you receive marketing email from TL by contacting us in respect of the same.
You can also exercise a variety of rights regarding our use of your data:
To exercise any of the foregoing rights, please contact us. We will evaluate your request in accordance with applicable data protection laws. TL will respond to your request within one month of receiving it. Also, note that you have the right to lodge a complaint with the UK Information Commissionerâ€™s Office or the supervisory authority in your country of residence or place of work.
5. What Data Do We Collect?
We donâ€™t receive any personal data about you other than what you provide to us or what you have consented for others to forward to us, or data we can infer from the Website Use.
When you register your interest in our product we will collect contact information about you and if you are an actual or prospective investor then we collect information as to how much you would like to invest. This will include your name, address, email address and investment amount. We will also ask you to provide AML information including your photo ID and proof of address.
We may ask you a series of questions relating to your financial circumstances and your understanding of the investment into which you propose to enter. These questions may take place via a recorded telephone conversation.
If you are an introducer you may be providing us with information about prospective third party investors and in such circumstances you must ensure that they have agreed to you providing us with their information. Where required by local laws, we would advise you to keep a record of their agreement and provide them with a copy of, or link to, this Policy. You should also only contact individuals who you know would be happy to hear from you.
6. What Happens If You Donâ€™t Want Us to Have Your Data?
You are not required to provide personal data to us. Note, however, that your failure to do so may affect our ability to provide the information that you request.
7. How Do We Use Your Data?
TL uses your personal data to provide you with information, to personalise your website experience, to send you communications and to keep you updated about the investment into which you have entered or may be considering entering.
We also use your data to help us make TL better and to advertise to you. We use your data to drive our research and development and to better understand our potential or actual investors. TL does this analysis using a variety of data sources, including transactional data (how you use the website), log data (web traffic and website usage), email data (how you respond to emails we send you), survey data, customer service data.
8. On What Legal Bases Do We Process Your Data?
We process your personal data on a variety of legal bases depending on the use. For example, we will only process your personal data to send you direct marketing if we have your consent and you can withdraw this consent at any time by opting out of receiving such emails. Sometimes it is necessary to process your data for us to comply with our legal obligations.
9. How Are We Using Your Data Based on Our Legitimate Interests?
We may process your personal data for the purposes of our legitimate interests, provided that these uses arenâ€™t outweighed by your rights or interests. What is a â€˜legitimate interestâ€™? It essentially means that we use your data in a way which might reasonably be expected as part of running our business and which doesnâ€™t impact materially on your rights, freedom or interests.
For example, we may use you investor profile to send you information about new products, or to keep you updated about similar products. We may also use your contact information to send you direct marketing information to tell you about related investment products that we think may be of interest to you.
For any uses we justify on the basis of legitimate interest, you have the right to opt out of such processing by writing to us or by informing us here.
10. With Whom Are We Sharing Your Data?
We may disclose your data to our affiliated organisations and subsidiaries, and to service providers who render services to us or you on our behalf (all of which are contractually obligated to act only on our instructions and in accordance with applicable laws, including GDPR). We also may disclose your information if required by law, requested by law enforcement authorities or to enforce our legal rights, such as pursuant to a subpoena. We may share your information in connection with a sale or reorganisation of TL, but in any such case, the terms of this Policy will continue to apply.
Our service providers include:
11. How Secure Is Your Data?
We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
12. Where Are We Sending Your Data?
TL stores usersâ€™ personal data inside the European Union. Some of our service providers and affiliated organisations may lie outside the EU. Therefore, sometimes we may transfer your data outside the EU. If we do, we ensure your data is processed only in countries that provide an adequate level of protection for your data or where the recipient provides appropriate safeguards, such as model contract clauses, binding corporate rules, or mechanisms like the EU-U.S. Privacy Shield framework. For a copy of such safeguards, please contact us.
13. How Long Do We Keep Your Data?
We keep your personal data in an identifiable form for as long as we have a legitimate reason to use the data and as required by law.
14. How Do You Complain?
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissionerâ€™s Office.
You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can't be responsible for the content of external websites).
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.