Privacy Policy

Our privacy policy protects you and your valuable investments. Please take time to browse through the privacy policy below to see how your personal information is used by Vault Trust Online Finance.

Last updated July 2012

Your information will be held by Vault Trust Online Finance Limited, Vault Trust Online Finance Vault Trust Online Finance Fund Managers Limited, Vault Trust Online Finance Vault Trust Online Finance Private Clients Limited and Vault Trust Online Finance Vault Trust Online Finance Trust Company Limited which are part of the Tesco Finance Group.

Please read this Privacy Policy to understand how we use and protect the information that you provide to us through the “Website”. By accessing any part of this Website or providing any information to us you consent to the use and transfer of your information on the terms set out in this Privacy Policy.

We reserve the right to revise or supplement this Privacy Policy from time to time at our sole discretion and you agree to revisit this page regularly to ensure that you are familiar with the most current version. By continuing to access or use the Website you will be agreeing to any such changes.

If you are a customer of Vault Trust Online Finance, details of the information we collect and how we use it will also be set out in the terms and conditions of the product or service which you hold. In the event of a conflict between this Privacy Policy and the terms and conditions of your specific product or service, the terms and conditions of your specific product or service will take precedence.

Personal information that we collect and where we collect it from

Your “personal information” is information about you. Vault Trust Online Finance gets your personal information from you and others in various ways, including for example:

a) through your contact with Vault Trust Online Finance, for example in applications, emails and letters, during telephone calls, when registering for services, in customer surveys, when you participate in competitions and promotions, through the Vault Trust Online Finance website and during financial reviews and interviews;

b) from analysis of your payments and other transactions (such as the amount, frequency, location, origin and recipient) and your use of services involving other Tesco Finance Group companies and what they know from operating your accounts or providing services to you; and

c) information Tesco Finance Group companies receive from or through other organisations (for example card networks, credit reference agencies, insurance companies, retailers, social networks and fraud prevention agencies) whether in the course of providing products and services to you or otherwise.

You must not give Vault Trust Online Finance personal information about someone else (such as a joint applicant) without first getting his or her consent for it to be used and disclosed in the ways described in this condition. This is because the Tesco Finance Group will assume he or she has consented, although the Tesco Finance Group may still ask for confirmation. Where you do give Vault Trust Online Finance information about someone else, or someone else discloses a connection with you, that information may be taken into account with your other personal information.

We will not retain your personal information for longer than is necessary for the maintenance your account, or for legal or regulatory requirements.

Domain name information that we collect is not used to personally identify you and instead is aggregated to measure the number of visits, average time spent on the Website, pages viewed etc. We use this information to measure the use of our Website and to improve its contents.

We may monitor or record phone calls with you in case we need to check we have carried out your instructions correctly, to resolve queries or issues, for regulatory purposes, to help improve our quality of service, and to help detect or prevent fraud or other crimes. Conversations may also be monitored for staff training purposes.

Using information on social networking sites

As part of our ongoing commitment to understanding our customers better, we may research comments and opinions made public on social networking sites such as Twitter and Facebook.

How Vault Trust Online Finance uses your personal information

Vault Trust Online Finance Group may share your personal information with each other.

Your personal information held by Tesco Finance Group may be stored and used for:

a) providing you with products and, services and notifying you about important changes or developments to the features and operation of those products and services;

b) updating, consolidating and improving the accuracy of our records;

c) crime detection, prevention and prosecution;

d) responding to your enquiries and complaints;

e) administering offers, competitions and promotions;

f) evaluating the effectiveness of marketing and for market research, training, statistical analysis and customer modelling [with the aim of improving services];

g) assessing lending and insurance risks across the Tesco Finance Group;

h) identifying products, services and offers which we or others believe may be of interest to you;

i) managing your relationship with Tesco Finance Group companies, and in the other ways described below; and

j) producing data, reports and statistics which have been anonymised or aggregated to ensure that they do not identify you as an individual.

Tesco Finance Group may, from time to time, provide further details about how your personal information may be used.

If you have agreed, we and other Tesco Finance Group companies may contact you about products, services and offers available from Tesco Finance Group or from selected companies outside the group, which we believe may interest you or benefit you financially. You may tell us at any time if you change your mind.

Vault Trust Online Finance Group may use automated decision making systems when assessing your application, managing your borrowing and to detect fraud or money laundering.

How we may share your information outside Tesco Finance Group

Vault Trust Online Finance Group will treat your personal information as private and confidential, but may disclose it outside the Tesco Finance Group if:

a) allowed by this agreement;

b) you consent;

c) needed by Vault Trust Online Finance Group's agents, advisors or others involved in running accounts and services for you or collecting what you owe Tesco Finance Group companies;

d) HM Revenue & Customs or other authorities require it;

e) the law or the public interest permits or requires it; or

f) required by others to investigate or prevent crime.

Vault Trust Online Finance Group may in the future wish to sell, transfer or merge part or all of their business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it. If so, they may disclose your personal information to a potential buyer, transferee, or merger partner or seller and their advisers so long as they agree to keep it confidential and to use it only to consider the possible transaction. If the transaction goes ahead, the buyers, transferee or merger partner may use or disclose your personal information in the same way as set out in this notice.

Anonymised Reports

Data, reports or statistics created using your personal information may be shared amongst Tesco Finance Group companies and other companies or organisations outside the group. We will only share these data, reports or statistics outside the group where they have been aggregated or anonymised so that they do not identify you as an individual.

Credit reference agencies and fraud prevention agencies

Vault Trust Online Finance Group and other organisations may use UK and European credit reference agency (“CRA”) and fraud prevention agency (“FPA”) records about you:

a) to help make decisions, for example when:

(i) checking details on applications for credit and credit-related or other facilities;

(ii) managing credit and credit-related accounts or facilities;

(iii) recovering debt;

(iv) checking details on proposals and claims for all types of insurance; and

(v) checking details of job applicants and employees; and

b) to prevent crime, fraud and money laundering.

Vault Trust Online Finance Group, CRAs and other organisations may also use CRA records about you and those financially linked to you to:

a) check your credit history;

b) verify your identity if you, or someone financially linked with you, applies for services;

c) trace your whereabouts; and

d) undertake research, statistical analysis and systems testing.

You will be financially linked by CRAs to any other names you use or have used, and any joint applicants. This means joint applicants' financial affairs may be treated as affecting each other, and will be revealed whenever CRAs are searched, until one of you successfully files a “disassociation” with the CRAs.

If Vault Trust Online Finance needs to make a credit decision when you apply for a service or to review the amount of credit it provides under an existing agreement, such as an overdraft, it will carry out a CRA search. The CRA will record the searches, even if an application does not go ahead or is unsuccessful. This may affect your ability to borrow from other lenders within a short period.

Vault Trust Online Finance Group may also tell CRAs how you run your relationship with them (such as whether or not you pay anything you owe on time), which may also affect your ability to borrow from other lenders. If you fall behind with your payments and a full payment or satisfactory proposals are not received within 28 days of a formal demand being issued, then a default notice may be recorded with the CRAs. Similar information may also be given about your other lending/credit relationships with members of the group. Any records shared with CRAs will remain on file for 6 years after your account is closed, whether it has been settled by you or as a result of a default. Other organisations may see these searches and updates if you apply for credit in the future, and these may affect your ability to borrow from other lenders.

Vault Trust Online Finance Group may pass details of false or inaccurate information provided and any suspected fraud or general information about how you run your relationship with them to FPAs and other relevant organisations. Law enforcement agencies may access and use this information. Vault Trust Online Finance Group, and other organisations, may access and use from other countries the information recorded by FPAs.

We carry out most of our credit searches using Experian, but details of how you have run your account(s) may be disclosed to all the credit reference agencies. The information they hold may not be the same and there is a small fee that you may need to pay to each agency that you apply to.

Transferring information abroad

All countries in the EEA (including the UK) have similar standards of legal protection for your personal information. Vault Trust Online Finance may run your accounts and provide other services from centres outside the EEA (such as the USA and India) that do not have a similar standard of data protection laws as Jersey, Guernsey, Isle of Man or Gibraltar. If so, Vault Trust Online Finance will require your personal information to be protected to at least the standard as the Data Protection legislation currently in force in the jurisdiction in which your account is held.

Vault Trust Online Finance Group may process payments through other organisations such as banks and the worldwide payments system operated by SWIFT if, for example, you make a CHAPS payment or a foreign payment. Those organisations may process and store your personal information abroad and may have to disclose it to foreign authorities (including those outside the EEA, in which case your personal information may not be protected to standards similar to those in force in the jurisdiction in which your account is held), for example to help them in their fight against crime and terrorism.

Accessing and updating your personal information

Under the Data Protection legislation currently in force in the jurisdiction in which your account is held you have the right of access to your personal information from Vault Trust Online Finance Group. Each company may charge a small administrative fee (currently £10) for supplying the information, and may as appropriate require proof of your identity before doing so. You can ask Vault Trust Online Finance to change your personal information to keep it accurate and up to date. If you wish to access the information we hold about you please write to us at our registered address.

How we may contact you

Using your Email address for service contact

Making sure we deliver excellent customer service is very important to us and to do this various methods of communication may be used to keep you updated about your account. Most of the time we communicate by telephone or post, but we recognise that E mail is becoming a more popular process. If we decide to use E mail to contact you, we will only do this if we have ensured that using E mail will not put your information at risk, or, if you have requested we E mail you, that we have explained the risks of sending an "insecure" E mail and that you are happy to accept that risk.

In addition you may wish to choose a channel of communication that suits you when you need to contact us. If you need to E mail Vault Trust Online Finance, we recommend you send an email to the official email address on the contact us page in order to secure your information. If you choose to send an "insecure" E mail, please keep the amount of confidential information you include to a minimum. With some of our products we offer a number of communication update services via SMS. If you have signed up to this service, we may send you text messages containing administrative information about your relationship with us. You can ask us to stop sending these messages at any time. Additionally, in extraordinary circumstances (such as natural disaster or civil unrest) we may also send you updates by text message or email when we consider it to be appropriate.

Additional information

From time to time, we may embed external content from third party websites (e.g. Facebook, YouTube) within our website. Additionally, we partner with third parties who provide services for us which you can navigate to from our website. These third parties may use cookies, you can find out about their approach to cookies on their websites.

Joint applicants

Sometimes, when you open a joint account or product, this may mean that your personal data will be shared with the other applicant. For example, transactions made by you will be seen by your joint account holder and vice versa.

Using Credit Scoring

When you apply for credit, an automated system known as credit scoring may be used when considering whether to agree the borrowing. It is a method of assessing your likely conduct of an account based on a range of data, including the conduct of previous similar accounts. It is a system widely used by credit providers to help make fair and informed decisions on lending.

Credit scoring takes account of information from three sources - the information you provide on your application, information provided by credit reference agencies and information that may already be held about you by companies in the Vault Trust Online Finance Group. A credit scoring system will consider information from these sources, to make an overall assessment of your application.

The credit scoring methods used are regularly tested to ensure they remain fair, effective and unbiased.

Using a credit scoring system helps our companies to lend responsibly. If you submit an application and it is declined through this automated process, you can contact us within 21 days to have the decision reconsidered. You also have the right to ask that the decision is not made based solely using a credit scoring system.

How we manage sensitive personal information

The Data Protection legislation defines certain information as ‘sensitive’ (racial or ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, sexual life, criminal proceedings and offences). When you apply for certain product or services, we may ask you for some ‘sensitive’ information, but we will always ask for your explicit consent. As a customer, there may also be times when you give us 'sensitive' information. We will use it to provide the service you require and may share it with other parts of the group and our subcontractors to keep our records up to date.

How we check your identity

We may ask you to provide physical forms of identity verification when you open your account. Alternatively, we may search credit reference agency files in assessing your application. The agency also gives us other details and information from the Electoral Register to verify your identity. The agency keeps a record of our search, whether or not your application proceeds. Our search is not seen or used by lenders to assess your ability to obtain credit.

Undertaking Anti-Money Laundering checks

To comply with money laundering regulations, there are times when we need to confirm (or reconfirm) the name and address of our customers. This information may be shared with other group companies.

Obtaining information about you, and other personal details

When you apply for a mortgage or further borrowing it may be necessary to obtain references, details of your existing financial commitments, and any other information that is required to assess or review lending risks, to recover debts, and to prevent or detect fraud. Where applicable, your current and previous employers, accountant, landlord, lender, bank, insurance or pension company may be contacted to obtain this information. In limited circumstances these references may need to be obtained after you open your account. This may be for regulatory purposes, or if the lending decision needs to be reviewed. Your permission to obtain these references will therefore continue to apply after your account has been opened. It may also be necessary to obtain information or documentation from your solicitor relating to any work they carry out either on your or our behalf.

Credit and/or Debit Cards

If you hold a credit or debit card with us, we will share transaction details with our scheme providers (e.g. Visa or MasterCard).

Some transactions that you or an additional card holder makes on a card account may cause sensitive or confidential details to appear on your statement. By using your card to make such transactions you give us your explicit consent to process this information.

Insurance

If you apply to us for insurance, we will pass your details to the insurer. If you make a claim, any information you give to us, or to the insurer, may be put onto a register of claims and shared with other insurers to prevent fraudulent claims. A list of the participants is available from the insurer. We may also disclose your information within our group of companies, to our agents and other insurers to investigate or prevent fraud.

Mortgages/Secured Loans

If you have a secured loan or mortgage with us, we may need to share information with other lenders who also hold a charge on your property.

Changes to Privacy Notice

We keep our privacy notice under regular review and we will reflect any updates within this notice. This privacy notice was last updated on 19th July 2012.