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Privacy Policy

Last updated: 14th March 2024

Date Version Summary of changes from last version
06-03-18 v1.1 General update to GDPR compliance
02-05-18 v1.2 Update relating to Credit Reference Agencies Information Notice (CRAIN)
21-05-18 v1.3 Updated links to SAR and Rectification/Erasure Forms
14-03-19 v1.4 Updated links to Cookie Policy (Section 3)
01-01-21 v1.5 Post Brexit Changes (section 7) and general updates
29-04-21 v1.6 Updated Registered address
15-01-23 v1.7 Full policy review and update

JustUs Privacy Policy

JustUs is the trading style of eMoneyHub Ltd. eMoneyHub Ltd takes your privacy very seriously and we give you our commitment to keep your personal data safe and secure. We will use the data for the purpose of which it was provided, and will not use it for any longer than necessary. This policy applies to both Investors and Borrowers alike and should be read in conjunction with our Terms and Conditions.

Information provided to us will be held by eMoneyHub Ltd on UK based servers. We will not hold, transfer or use your data outside the European Economic Area (EEA), nor will we share it with others, within or outside of the EEA (except when we believe in good faith that the law requires it).

We will not without your express consent provide your personal information to any third parties for the purposes of direct marketing.

A copy of this policy can be downloaded here.

1. Information collected by eMoneyHub Ltd

We collect, store and use the following personal information in a secure environment:

  • Your contact and identity data: Name, address, date of birth, telephone numbers, email address, marital status, dependents,gender, username and passwords (eMoneyHub Ltd websites only), Feedback.

  • Special category data: Ethnicity and/or race, details of convictions relating to criminal offences, vulnerablity information relating to you and/or persons in your household, such as children or elderly people, or other information we may require to comply with guidelines on matters of public health or concern.

  • Financial data: Income and expenditure, credit worthiness, bank account details, employment status, open banking data (including details of your transactions with other financial institutions), Tax Status, potential changes in your circumstances which may affect your ability to repay any loan, or impact any investment.

  • Technical data:Your IP address, browser, time zone setting, location data referral source, length of visit and number of JustUs.co page views.

  • Usage data: Including how you use our website, products and services, the full uniform resource locators of any links used within, through and from our site (including date and time), download errors, length of visit, page interaction information, methods to browse away from the page. Any correspondence or emails you send to us, records of telephone conversations between us, or questions you ask the JustUs representatives.

  • Initial contact:A basic product enquiry form which could include your mobile number, home address, email address, marital status, financial dependents, and other personal information. Any emails you send to us by way of an enquiry, and records of telephone conversations between us.

  • Marketing and communications data: your marketing preferences from us and and your communication preferences

  • Any additional information: that is gathered as part of the application and assessment process to confirm your eligibility for any product or service offered by JustUs.

The information may come from (but not limited to) information provided by you during the application process, Credit Reference Agencies (see section 6), your financial services providers, companies that introduce your business to us, Fraud Prevention Agencies (such as CIFAS), Information services such as Companies House or Government Agencies, His Majesty's Land Registry (HMLR), and Law Enforcement Agencies.

We may monitor, record and store communications via telephone, email or written correspondence. We will use this information for verification purposes to ensure your needs are met as well as for training and compliance purposes to improve our customer service.

We will collect information from you in a number of ways dependent on how you choose to contact us.

  • Direct: This is where you contact eMoneyHub Ltd via our website, online forms, direct telephone communications or in writing via email or traditional postal communication. It will also include communications received via our social media presence.

  • Third-parties: This is where you have been referred to us by an introducer or broker, and will include information provided to us by the third-party.

2. Your rights as an individual.

Under the EU General Data Protection Regulation (GDPR), your rights relating to privacy and data protection changed. These rights are:

  • The right to be informed - have the right to be informed about the collection and use of your personal data.

  • The right of access - You have a right to request access to the personal information we hold about you, this is also known as a subject access request (see section 9).

  • The right to rectification You can request that we update and correct any out of date or inaccurate personal information we hold about you; You can do this by contacting us (see section 9).

  • The right to erase - In some circumstances you can request that we remove all personal information we hold about you if there is no need for us to keep it. You can do this by contacting us (see section 9).

  • The right to restrict processing - If we process your data, you can request that we stop or restrict the processing of your personal information.

  • The right to data portability - You can make a request for us to provide personal information you have supplied to Kuflink to a third party. Please be aware that there may be regulatory or legal reasons why we cannot satisfy your requests, but we will advise you of this when a request is made.

  • The right to object - the right to object to the processing of your personal data in certain circumstances.

  • Rights in relation to automated decision making and profiling - You have rights relating to automated individual decision-making (making a decision solely by automated means without any human involvement); and profiling (automated processing of personal data to evaluate certain things about an individual). Profiling can be part of an automated decision-making process.

Further information on the above is available from the 'Information Commissioner's Office' website.

3. Cookies use on JustUs.co

We use cookies on the JustUs.co website.

We will send cookies to you (which may be stored by your browser on your computer's hard drive) for the following purposes:

  • For identification: cookies allow us to identify you while you are logged in.
  • To record third party websites product purchases and or applications and specifically, we use cookies on JustUs.co for use with Google and their related conversion tools and tracking analytics. The visitor information generated creates reports on the use of JustUs.co website. Google stores this information, although many of the cookies they use are deleted when you close your browser.

Additional information is available here.

4. JustUs and your personal information

Applications or enquiry forms submitted via JustUs.co will only be used for the purposes specified in this Privacy Policy and the 'use of personal data' statement you acknowledge on the form prior to submission.

We process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and verifying the identity of borrowers and lender, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the investment services and/or loan finance you have requested.

The General Data Protection Regulation states that we can only use personal information if we have a genuine reason to do. This includes providing it to third parties outside of eMoneyHub and it's associated companies. We will only use your information for one of the following reasons:

  • - To fulfil a contract, we have with you
  • - When it is our legal duty
  • - When you consent to us
  • - When it is in our legitimate interest

The table below demonstrates how we can use your personal information and the reasons we do so.

What we use your personal information for When we use your personal information Our legitimate interests
To provide an initial loan quotation Our legitimate interest Ensuring customers have a clear understanding of their product eligibility without having a detrimental impact on their credit rating
To manage our existing relationship with you Fulfilling Contracts -
To manage the products and services you have with us Fulfilling Contracts or consent -
To keep you updated about our products and services Our legitimate interest or consent Keeping existing customers up to date with the products and services that we offer
To develop and/or test new and existing products Our legitimate interest or consent Identifying customer groups, their needs and preferences and to develop products and services that are suitable for customers and meet expectations, to improve our customers' experience
To analyse how customers use our products and services Our legitimate interest or consent Identifying customer groups, their needs and preferences and to develop products and services that are suitable for customers and meet expectations, to improve our customers' experience
To develop and carry out marketing activities Our legitimate interest or consent Keeping new and existing customers up to date with the products and services that we offer
To allow us to work with other companies that provide services to us and our customers Fulfilling Contracts -
To operate/provide lending and investment services Fulfilling Contracts -
To handle payments received from borrowers Fulfilling Contracts -
To apply charges, fees, and interest due on customer accounts; to recover and collect money that is owed Fulfilling Contracts -
To detect, investigate, report, and seek to prevent financial crime Our legal obligation -
To control risk for us and our customers Our legitimate interest and our legal obligation Developing appropriate products and services, reviewing fees and charges and who we will provide them to, complying with regulations that apply to us and monitoring and mitigating risks
To obey laws and regulations that apply to us Our legal obligation -
To acknowledge complaints and look to resolve them Our legal obligation -
To exercise our rights set out in agreements or contracts Fulfilling Contracts -

When processing your personal data, decisions may be made by automated means. This means we may automatically decide that you pose a risk if our processing reveals your behaviour is consistent with money laundering or known fraudulent conduct, or is inconsistent with your previous submissions, or you appear to have deliberately hidden your true identity. You have rights in relation to automated decision making: if you want to know more.

Information you enter into a specific product search or enquiry form may be shared with third parties such as credit reference and fraud prevention agencies. Where required all the companies we work with are FCA regulated. There may be circumstances where we are required by law to provide your information.

Prior to submission of your personal information, we will ensure that you have access to this privacy policy. We will gather your express permission to use the data you entrust us with before you provide it to us.

As an Information Controller we may use the data you provide in a number of ways. These may include:

  • - To further support the development of products and services within the JustUs group; to assess lending and credit risks; to carry out regulatory checks; for fraud and creditworthiness checks; specific marketing and updates on your account.
  • - Where we feel information is deliberately misleading or fraudulent, we reserve the right to pass details to fraud prevention agencies;
  • - We may use your information to assess and prevent fraud and money laundering.

We will keep your personal information secure and whilst in our possession will maintain its confidentiality. We will only share your information where you have given your express permission. This will generally be with credit reference and identification verification agencies during the application process for both borrower and investor accounts. Following a credit approval, we will share details of the conduct of your account with the same agencies. Investor information will be shared with HMRC annually as part of our obligations and the specified bank that you have advised us of during your application for the purposes of making payments to you.

5. Personal information security

eMoneyHub Ltd treat the security of your personal information seriously. eMoneyHub Ltd take reasonable technical and organisational precautions to prevent the loss of your data.

We store information you provide in our secure database. All pages on the JustUs.co website relating to your personal information are protected using SSL technology.

We will hold your personal information for as long as you have a relationship with us, e.g., you have applied for a product or you are an existing customer of ours, and for a period of time after our relationship ends e.g., your application was declined, you have closed your account. How long we hold your information depends on the nature of our relationship, the type of information and the purposes for which we hold it.

Viewing of your data will be restricted to those persons who require access for the purposes the information was provided to us in the first instance. Any further use of the data will be in accordance with your express wishes provided at the time of submission or where you advise in the future.

Your data will be securely retained for the duration of your relationship with eMoneyHub Ltd. During this period the data will be used within the guidelines of this policy. Following the end of your relationship with eMoneyhub Ltd the data will be retained for a further 6 years or up to the point you successfully exercise your right to erasure of your data.

The information we hold about you will support us to:

  • - Comply with our legal and regulatory requirements, e.g., anti-money laundering laws and laws that require us to keep details of financial transactions we have undertaken such as loan repayments and investor payments)
  • - Instigate, exercise, and defend legal claims
  • - Deal with any complaints received in relation to our products and services
  • - Maintain records for analysis and audit purposes
  • - Pursue our or third party’s legitimate interest, e.g., developing and improving credit risk models e.g., borrower data will be retained/examined and provided to credit reference agencies so they can use it for the purposes outlined in section 6.
  • - Prevent and detect fraud
  • - Ensure we do not send unsolicited marketing communications

We are unable to guarantee the security of data sent over the internet or via email.

6. Credit Reference Agency Information Notice (CRAIN)

In order to process your application, we will perform credit and identity checks on you with one or more credit reference agencies ('CRAs'). Where you take banking services from us we may also make periodic searches at CRAs to manage your account with us.

To do this, we will supply your personal information to CRAs and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.

We will use this information to:

  • - Assess your creditworthiness and whether you can afford to take the product;
  • - Verify the accuracy of the data you have provided to us;
  • - Prevent criminal activity, fraud and money laundering;
  • - Manage your account(s);
  • - Trace and recover debts; and
  • - Ensure any offers provided to you are appropriate to your circumstances.

We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs.

For further information please use the links below:

7. Sending your data outside of the United Kingdom

eMoneyHub Ltd hold your data securely inside the UK. We do not, as part of our normal business activities, transfer your information outside the UK. Should we be required to transfer your data outside of the UK we would only do so if the entity receiving the data provide adequate safeguards (where your rights would be enforceable and effective legal remedies available following the transfer) or where you had provided informed consent

In the event that we were forced to share data with an organisation outside of the UK and in a jurisdiction that is not regarded as having adequate levels of protections for personal data, e.g. because we were required by law to disclose information, we would seek to ensure that the recipient organisation agreed to protect the data to levels equivalent to that of the UK and seek to put in place appropriate safeguards to ensure that the data was adequately protected. If that was not possible, we would ensure the sharing of the data was lawful.

8. Amendments to the JustUs.co privacy policy

eMoneyHub Ltd reserve the right to update this Privacy Policy at any time by posting a new version on this website. We recommend reviewing the privacy policy on a regular basis.

9. Accessing the data we hold about you.

You can request confirmation of the information we hold on our secure servers about you at any time. This information is generally free of charge however we retain the right to make a realistic administration charge to comply with complicated, manifestly unfounded or excessive requests. We may also make a charge for repeat requests. Any charge will be notified in writing including the reason we are making the charge.

We will action all requests for information without delay and within 1 calendar month of the initial request being made.

To support any requests, there are 2 documents available to ensure we receive the information we require to effectively complete any queries.

You can make decisions as to whether you wish to opt out at any time from receiving any marketing information from JustUs.co by click the Opt Out link at the bottom of any of our email communications.

10. Contact details

We are registered with the Information Commissioner's Office: Number ZA589341

Data Protection Officer, JustUs, Block 1 G82 Alderley Park, Congleton Road, Nether Alderley, Macclesfield, Cheshire SK10 4TG

11. Making a complaint to the Information Commissioner's Office

If you have any concerns about our use of your personal information, you can make a complaint to us using the contact details in point 10 above.

If you are unhappy with our response to any queries you make pertaining to your personal data and its use you can voice your concerns to the Information Commissioner's Office.

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk.

THINK CAREFULLY BEFORE SECURING OTHER DEBTS AGAINST YOUR HOME. YOUR HOME MAY BE REPOSSESSED IF YOU DO NOT KEEP UP REPAYMENTS ON A MORTGAGE OR ANY OTHER DEBT SECURED AGAINST IT. IF YOU ARE THINKING OF CONSOLIDATING EXISTING BORROWING YOU SHOULD BE AWARE THAT YOU MAY BE EXTENDING THE TERMS OF THE DEBT AND INCREASING THE TOTAL AMOUNT YOU WILL REPAY.