Privacy policy

Trinity Pawnbrokers is a trading name of Open Access Finance Ltd, which also trades as Unbolted and is authorised and regulated by the Financial Conduct Authority under firm reference number 741896. The policy below is published by Open Access Finance Ltd and applies to your Trinity loan.

What does the firm do?

Open Access Finance Ltd, trading as Unbolted and as Trinity Pawnbrokers, respects your right to privacy. This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights.

If you have any questions or concerns about our use of your personal information, please contact us using the details at the bottom of this notice. We recommend that you read this notice in full to ensure you are fully informed.

What personal information do we collect, and why?

The personal information that we may collect about you broadly falls into the following categories.

Information that you provide voluntarily

Certain parts of our website may ask you to provide personal information voluntarily: for example, we may ask for your contact details in order to register an account with us or to submit enquiries to us, either as a prospective lender, borrower or introducer. We may also ask you to provide your name, date of birth, residential address and banking details, so we can perform identity and fraud prevention checks on you. The personal information you are asked to provide, and the reasons why, will be made clear to you at the point we ask for it.

Information that we collect automatically

When you visit our website, we may collect certain information automatically from your device. In the United Kingdom and the European Economic Area, this information may be considered personal information under applicable data protection laws.

Specifically, the information we collect automatically may include your IP address, device type, unique device identification numbers, browser type, broad geographic location (for example country or city-level location) and other technical information. We may also collect information about how your device has interacted with our website, including the pages accessed and links clicked.

Collecting this information enables us to better understand the visitors who come to our website, where they come from, and what content is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of the site.

Some of this information may be collected using cookies and similar tracking technology, as explained under "Cookies and similar tracking technology" below.

Identity checks

In order to process your application, we will perform identity checks on you with one or more credit reference agencies. To do this, we will supply your personal information to those agencies and they will give us information about you. The information we provide will include your name, address, date of birth and banking details. The agencies will supply information that is public, including the electoral register, as well as financial history information such as bankruptcy or a county court judgment, and fraud prevention information.

We will use this information to:

• verify the accuracy of the data you have provided to us; and
• prevent criminal activity, fraud and money laundering.

We will not exchange any credit related information with the credit reference agencies, including information about any outstanding debt or settled accounts. We will also not ask them to supply us with shared credit or financial situation information about you. They will not place a credit search footprint on your credit file, although they may place an identity search footprint.

Who else do we share your personal information with?

We may disclose your personal information to the following categories of recipient:

• third party service providers and partners who provide data processing services to us, for example to support the delivery of, provide functionality on, or help to enhance the security of our website, or who otherwise process personal information for purposes described in this notice or notified to you when we collect your personal information;
• any competent law enforcement body, regulatory or government agency, court or other third party where we believe disclosure is necessary as a matter of applicable law or regulation, to exercise, establish or defend our legal rights, or to protect your vital interests or those of any other person;
• an actual or potential buyer, and its agents and advisers, in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this notice;
• any other person with your consent to the disclosure.

Legal basis for processing personal information

Our legal basis for collecting and using the personal information described above depends on the personal information concerned and the specific context in which we collect it.

We will normally collect personal information from you only where we need it to perform a contract with you, where the processing is in our legitimate interests and not overridden by your rights, or where we have your consent. In some cases we may also have a legal obligation to collect and process personal information about you, for example to report a potential fraud to the National Crime Agency.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether providing it is mandatory, as well as the possible consequences if you do not. For example, to borrow or lend through our platform you will need to provide relevant personal information so we can carry out identity and fraud prevention checks, manage and administer your account, make or receive payments, contact you about your account and respond to your queries. If you do not wish to provide this information, you will not be able to proceed with your application.

If we collect and use your personal information in reliance on our legitimate interests, or those of any third party, that interest will normally be to operate our platform and communicate with you as necessary to provide our services, and for our legitimate commercial interest — for instance improving the platform, undertaking marketing, or detecting and preventing illegal activity.

Cookies and similar tracking technology

We use cookies and similar tracking technology to collect and use personal information about you. For further information about the types of cookies we use, why we use them, and how you can control them, please see our cookie policy.

How we keep your personal information secure

We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measures include serving our website and all forms carrying personal data over a secure encrypted connection, and storing personal data in a database with access rights restricted on a need-to-know basis.

International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.

Specifically, some of the third party service providers and partners we use operate around the world. This means that when we collect your personal information we may process it in any of those countries.

We have taken appropriate safeguards to require that your personal information remains protected in accordance with this notice. We only appoint third party service providers who provide us with sufficient guarantees that they will comply with relevant data protection laws.

Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so, for example to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible — for example because your personal information has been stored in backup archives — we will securely store it and isolate it from any further processing until deletion is possible.

Your data protection rights

You have the following data protection rights:

• if you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the details below;
• you can object to processing of your personal information, ask us to restrict processing, or request portability of your personal information;
• you have the right to opt out of marketing communications we send you at any time. You can exercise this right by clicking the unsubscribe or opt-out link in the marketing emails we send you. To opt out of other forms of marketing, such as postal marketing or telemarketing, please contact us using the details below;
• if we have collected and processed your personal information with your consent, you can withdraw that consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted before you withdrew it, nor will it affect processing conducted in reliance on lawful grounds other than consent;
• you have the right to complain to a data protection authority about our collection and use of your personal information. In the United Kingdom this is the Information Commissioner's Office.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Updates to this notice

We may update this notice from time to time in response to changing legal, technical or business developments. When we do, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material changes if and where this is required by applicable data protection laws.

You can see when this notice was last updated by checking the date shown at the top of this page.

How to contact us

If you have any questions or concerns about our use of your personal information, please contact us at support@unbolted.com.

The data controller of your personal information is Open Access Finance Ltd.