Qlarifi Limited Privacy Policy
Qlarifi Limited, a company registered in England and Wales, with company number, 15212022 (we, us or our), understands that protecting your personal data is important. This Privacy Policy sets out our commitment to protecting the privacy of personal data provided to us, or otherwise collected by us when providing our website and consumer credit checking service (Services) or when otherwise interacting with you.
It is important that you read this Privacy Policy together with any other detailed privacy notices we may provide when we are collecting or processing personal data about you so that you understand our privacy practices in relation to your data.
The information we collect
Personal data: is information that relates to an identified or identifiable individual.
We may collect, use, store and disclose different kinds of personal data about you which we have listed below:
Identity Data including first name, middle name, last name, title, date of birth and gender.
Contact Data including billing address, delivery address, email address and telephone numbers.
Consumer Financial Data including details about payments and/or non-payments from consumers to our customers, describing factors such as the type of contract, amount, and timeliness of repayments.
Technical and Usage Data including internet protocol (IP) address, your browser session, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour, information about your access and use of our website, including through the use of Internet cookies, your communications with our website, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider.
Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
How we collect personal data
We collect personal data in a variety of ways, including:
Directly: We collect personal data which you directly provide to us, including when you sign up as a client, through the ‘contact us’ form on our website or when you request our assistance via email, or over the telephone.
Indirectly: We may collect personal data which you indirectly provide to us while interacting with us, such as when you use our website, in emails, over the telephone and in your online enquiries.
From third parties: We collect personal data from third parties including lenders and details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.
Purposes and legal bases for processing
We collect and process personal data about you only where we have legal bases for doing so under applicable laws, and in particular, for purposes related to the assessment, assumption or management of credit risk, the assessment of the reliability and punctuality of the interested party in payments.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please reach out to us at contact@qlarifi.com if you need further details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
If you have consented to our use of data about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your data because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using our services. Further information about your rights is available below.
Decisioning and profiling
We do not make underwriting decisions or any form of profiling suggestions to lenders and data recipients. Lending decisions remain at the entire discretion of the lenders. We only provide information to support the lenders in making their decision, and each lender makes decisions completely autonomously through the application of their own policies and criteria.
Our disclosures of personal data to third parties
We may disclose personal data to:
lenders with whom you have an existing relationship;
our employees, contractors and/or related entities;
IT service providers, data storage, web-hosting and server providers such as Amazon Web Services (AWS);
professional advisors, bankers, auditors, our insurers and insurance brokers;
payment systems operators;
our existing or potential agents or business partners;
anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; and
any other third parties as required or permitted by law, such as where we receive a summons.
Google Analytics: We may enable Google Analytics Advertising Features including Remarketing Features, Advertising Reporting Features, Demographics and Interest Reports, Store Visits, Google Display Network Impression reporting etc. We and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together.
You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here. To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.
Data storage and transfers
The personal data we receive is stored in Italy and the European Union. Where we transfer your personal data outside of the European Union, we will ensure the adoption of appropriate safeguards and standards in accordance with the requirements of the GDPR and we will protect the transferred personal data in accordance with this Privacy Policy. Our data protection safeguarding includes:
only transferring your personal data to countries that have been deemed by applicable data protection laws to provide an adequate level of protection for personal data, at least as much protection as the GDPR; or
including standard contractual clauses in our agreements with third parties that are overseas to ensure best practices in data protection and security.
Where we disclose personal data to the third parties listed above, these third parties may store, transfer or access personal data outside of the European Union, including the United States of America. The level of data protection in countries outside of the UK and European Union may be less comprehensive than what is offered in the United Kingdom and European Union.
Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
For all processing relating to data subjects in Italy, our data retention schedule follows the retention periods established in the Italian Code of Conduct for the processing of personal data in the field of commercial information:
Personal data relating to credit requests
Up to 180 days, or in the case of denied requests up to 90 days.
Your rights and controlling your personal data
Your choice: Please read this Privacy Policy carefully. If you provide personal data directly to us, you understand we will collect, hold, use and disclose your personal data in accordance with this Privacy Policy. You do not have to provide personal data to us, however, if you do not, it may affect our ability to provide our Services to you and your use of our Services.
Information from third parties: If we receive personal data about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal data about somebody else, you represent and warrant that you have a lawful basis under the GDPR for the transfer and processing of the personal data.
Access, correction, processing and portability: You may request details of the personal data that we hold about you and how we process it (commonly known as a “data subject request”). You may also have a right in accordance with applicable data protection law to have your personal data rectified or deleted, to restrict our processing of that information, to object to decisions being made based on automated processing where the decision will produce a legal effect or a similarly significant effect on you, to stop unauthorised transfers of your personal data to a third party and, in some circumstances, to have personal data relating to you transferred to you or another organisation.
Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.
Withdraw consent: Where we are relying on consent to process your personal data, you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk).
In Italy, the interested party also has the right to lodge a complaint with the Guarantor for the protection of personal data (www.garateprivacy.it), or with the Monitoring Body of the SIC Code of Conduct (www.odmsic.it).
Storage and security
We are committed to ensuring that the personal data we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal data and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.
Cookies
We may use cookies on our website from time to time. Cookies are text files placed in your computer's browser to store your preferences. For more information about the cookies we use, please see www.qlarifi.com/cookies.
Links to other websites
Our website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal data which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.
Amendments
We may change this Privacy Policy from time to time, and notify you by publishing an updated version on our website. If we make a significant change to this Privacy Policy, we may also contact you through the contact details you have provided to us. For any questions or notices, please contact us at:
Qlarifi Limited, a company registered in England and Wales, with company number, 15212022.
Email: contact@qlarifi.com
Last update: 28 January 2025