Privacy Policy

Last updated in September 2023.

This Privacy Notice (“Privacy Notice”) sets out how Specialist Lending Limited (SLL) trading as “Duologi”, processes your personal data in connection with any finance agreements you hold or have applied for with us in relation to our point-of-sale payment services and also the provision of the website (the “Site”), at https://duologi.com (together our “Services”).

1. PURPOSE OF THIS PRIVACY POLICY

This Privacy Notice explains our approach to any personal data that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal data. This Privacy Notice also sets out your rights in respect of our processing of your personal data.

For more information click here.

When we talk about “personal data”, we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them, such as their physical appearance.

This Privacy Notice informs you of the nature of the personal data about you that is processed by us and how you can request that we delete it, update it, transfer it and/or provide you with access to it.

This Privacy Notice is intended to assist you in making informed decisions when using the Site and our Services. Please take a moment to read and understand it. It should be read in conjunction with our Terms of Service and our Cookie Policy.

This Privacy Notice only applies to the use of your personal data obtained by us, whether from you directly or from a third party. It does not apply to personal data collected by third parties during your communications with those third parties or your use of their products or services (for example, where you follow links to third party websites over which we have no control, or you purchase goods or services from those third parties).

2. ABOUT US

The Site and our Services are made available by Specialist Lending Limited, which is a private company registered in England & Wales which also uses the trading names “Duologi” and “Purplebricks Payment Services”, this Privacy Notice will therefore also apply in respect of each of these brands and any other future trading names we may choose to adopt (“Duologi“, “we”, “us, “our”).

SLL is the data controller responsible for your personal data.

For more information click here.

Specialist Lending Ltd (company no: 10664999) is an English company with its registered office at The Square, Basing View, Basingstoke, England RG21 4EB.

3. How to contact us

If you have any questions about this Privacy Notice or want to exercise your rights set out in this Privacy Notice, you can contact us by:

using the Contact Form on our Site
sending an email to complaints@duologi.com
calling 0345 5211 881
writing to Duologi, The Square, Arena, Basing View, Basingstoke, Hampshire RG21 4EB

4. How we collect and receive personal data

We collect and receive personal data using different methods:

Personal data you provide to us

You may give us your personal data directly. This will be the case when, for example, you contact us with enquiries, complete forms on our Site, apply for any finance agreements, subscribe to receive our marketing communications or provide feedback to us.

Personal data we collect using cookies and other similar technologies

When you access and use our Site, we will collect certain technical information about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies (see the “Our use of cookies and similar technologies ” section below).

Personal data received from third parties and merchants

From time to time, we will receive personal data about you from third parties. Such third parties may include analytics providers, our third-party merchant partners, credit reference agencies and third parties that provide technical services to us so that we can operate our Site and provide our Services.

5. Who we collect personal data about

We collect and process personal data from the following people:

Site visitors

If you browse our Site, register as a merchant on our Site, contact us with an enquiry through our Site, submit a complaint through our Site or use any Services available on our Site, we will collect and process your personal data in connection with your interaction with us and our Site.

Customers

If you apply for finance from us, we may collect and process your personal data in connection with the supply of such finance.

Director or beneficial owner of customers

We may collect and process your personal data as provided to us by the main guarantor.

Estate Agencies/TPO

If you have instructed an estate agent and we have been assigned the right by the estate agent to collect your service fees and/or payments, we may collect and process your personal data in connection with the provision of this service, including in connection with any complaint you may raise with the estate agent or which you may refer to an alternative dispute resolution service (such as The Property Ombudsman).

Financial Associates

If you are making a joint application or tell us that you have a spouse or financial associate, we will obtain personal information about any financial associates from the CRAs.

Job applicants

If you apply for a job with us, whether through the Site or otherwise, we will collect and process your personal data in connection with your application.

Partners who have introduced you to us

We will receive information from some of our partners whom we have introducer arrangements with.

6. Personal data we collect and how we use it

We use your personal data for the following purposes:

Fulfilment of our Services

We collect and maintain personal data that you submit to us for the purpose of processing your finance application, whether submitted to us directly or indirectly via our partners, analysing your suitability for finance, maintaining our finance agreement with you and where needed, establishing contact you with.

We may collect and process your personal data whether you are interacting with us directly or via a merchant partner of ours. We will receive customer applications via our own platform and platforms maintained by third parties, such as the merchant who you may refer you to us.

The personal data we process may include your name and contact information (such as email address, postal address and telephone number), your payment information (such as annual salary and bank details). We process this information so that we can fulfil the supply of Services, maintain our user databases and to keep a record of how our Services are being used.

Our legal basis for processing

It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you directly or via one of our merchant partners, or it is in our legitimate interest or a merchant’s legitimate interest to use personal data in such a way to ensure that we provide our Services in an effective, safe and efficient way.

Use of our site

We collect and maintain personal data that you submit to us during your use of our Site in the following ways:

Submitting your finance application.

The Services we provide require you to register with us and submit a finance application for us to process. We will ask all prospective applicants to complete the registration form, providing a username, email address and password as well as information about your address history, contact details, gender, age, employment status and your bank details.

We will use your personal data in order to process your finance application and in order to create an online customer account. Once you are registered, we will process your username and password to identify you when you login to your account and the secure areas of our Site. We will also process your login information so that we can administer your account and contact you about your account.

Your access to and use of our Site, including any secure customer/merchant areas, is subject at all times to our Terms of Use.

Our legal basis for processing

It is necessary for us to use your personal data to perform our obligations in accordance with any finance agreement or other contract that we may have with you for the relevant Services.

Customer service and general enquiries.

Our Site features a “Get in Touch” page which invites you to submit general enquiries about our Site and our Services by email, telephone or via the Site directly.

When you make an enquiry, we will collect and process your name, contact information (including email address and/or telephone number) and any other personal data that is relevant to your enquiry. We use this information to manage and respond to your enquiry.

We also record (including voice recordings of telephone conversations) and use the information referred to above to train our personnel so that they can effectively deal with enquiries.

Our legal basis for processing

It is in our legitimate interest to use your personal data in the ways described above to ensure that we are able to help you with your enquiry and provide a good standard of service to you.

Insight, analysis and retargeting through Cookies

We and our third-party partners use cookies, web beacons, pixel tags and other similar technologies (which we generically refer to as “Cookies”) to collect data from the device(s) that you use to access our Site (including any emails that you receive from us). The data that is collected includes the following:

an IP address to monitor Site traffic and volume;
a session ID to track usage statistics on our Site;
information regarding your demographics, experiences with our Site and our Services; and
information regarding your contact preferences.

Please see our Cookie Policy for further information, including details of the third-party partners that are used.

We and our third-party partners use this data, in combination with your contact information and other information that we have collected about you, for the following purposes:

for the purposes described in the Online personalised advertising section below and the Advertising to other people who share similar interests and characteristics to you;

to analyse how you use, and the effectiveness of, our Site and Services, including:
- to count users who have visited our Site or opened an email and collect other types of information, including insights about our visitors’ browsing habits, which helps us to improve our Site, Services and the effectiveness of our emails;
- to measure the effectiveness of our content;
- to learn what pages of our Site are most attractive to our visitors, which parts of our Site are the most interesting and what kind of features and functionalities our visitors like to see; and
- to help us with the selection of future product and service lines, website design and to remember your preferences.

Our legal basis for processing

Where your data is collected through the use of Cookies, we rely on consent to collect your data. Please see our Cookie Policy for further details.

However, we may rely on other legal basis when we use your personal data that has been collected via the use of Cookies for the purposes described in this section.

Where we use this personal data to analyse how you use our Site and Services, it is in our legitimate interest to use your personal data in such a way to improve our Site and our Services.

Recruitment

We use your personal data for recruitment purposes, in particular to assess your suitability for any of our positions that you apply for, whether such application has been received by us online, by email or by hard copy and whether submitted directly by you or by a third-party recruitment agency on your behalf.

We also use your personal data to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal and regulatory obligations in relation to recruitment.

We will process any personal data about you that you volunteer, including during any interview, when you apply for a position with us. We may also process your personal data obtained from any third parties we work with in relation to our recruitment activities, including without limitation, recruitment agencies, background check providers, credit reference agencies and your referees.

The personal data we process may include your name and contact information (including your email address, postal address, and telephone number), details of your education, qualifications and employment history, any other personal data which appears in your curriculum vitae or application, any personal data that you volunteer during an interview or your interactions with us, or any personal data which is contained in any reference about you that we receive. Such information may also include special categories of personal data (such as information about your health, any medical conditions and your health, sickness records, and any other special category data.) and information relating to criminal convictions and offences if that information is relevant to the role you are applying for.

We also use your personal data for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit.

Our legal basis for processing

Where we use your personal data in connection with recruitment, it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal data in such a way to ensure that we can make the best recruitment decisions.

We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.

Receipt of services from our suppliers

If we have engaged you or the organisation you represent to provide us with products or services (for example, if you or the organisation you represent provide us with services such as applications/functionality, data processing or IT services and support, payment services, probate service providers, communications service providers we will collect and process your personal data in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide our Services to our customers.

The personal data we collect from you may include your name, job title, contact information (including email address, telephone number and postal address), bank account or other payment details and any other personal data you volunteer which is relevant to our relationship with you or the organisation you represent.

Our legal basis for processing

It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you or it is in our legitimate interest to use personal data in such a way to ensure that we have an effective working relationship with you or the organisation you represent and are able to receive the services that you or your organisation provides, and provide our Services to others, in an effective way.

Receipt of services from our suppliers

Our legal basis for processing

Legal and regulatory compliance

We use your personal data for the following business administration and legal compliance purposes:

to comply with our legal obligations;
to enforce our legal rights;
to protect the rights of third parties;
to prevent criminal activity, fraudulent behaviour and money laundering; and
in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of all or a portion of our assets.

Our legal basis for processing

Where we use your personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we have a legal obligation to use your personal data to comply with any legal obligations imposed upon us such as a court order.

7. If you fail to provide your personal data

Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data we need in order to provide the Services you have requested from us or to process an application for employment with us. In this case, we may have to cancel your application or the provision of the relevant Services to you, in which case we will notify you.

8. Our use of cookies and similar technologies

Our Site may use certain cookies, web beacons, pixel tags, log files and other technologies. Please see our Cookie Policy to find out more about the cookies and other similar technologies we use, the purposes for which we use them and how to manage, block or delete them.

9. Third party links and services

This Privacy Notice does not apply to your interaction with any of our merchant partners or any other third parties.

Our Site may contain links to merchant partners and other third-party websites and services

When you use a link to go from our Site to another website (even if you don’t leave our Site) or you request a service from a merchant partner or other third party, this Privacy Notice shall not apply to the processing of your personal data carried out by the relevant merchant or third-party provider.

Your browsing and interactions on any other websites, or your dealings with any merchant or other third party service provider, is subject to that website’s or third party service provider’s own rules and policies.

We do not monitor, control or endorse the privacy practices of any third parties.

We encourage you to become familiar with the privacy practices of every website you visit or merchant / third-party service provider that you use in connection with your interaction with us and to contact them if you have any questions about their respective privacy notices and practices.

This Privacy Notice applies solely to personal data processed by us through your use of our Site, your receipt of our Services and/or in connection with our business operations. It does not apply to the processing of your personal data by our merchant partners or any other third-party websites and third party service providers.

10. Sharing personal data

We will only share personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations.

For more information, click here

When processing your personal data, we may need to share it with third parties as follows:

Third-party organisations that provide applications/functionality, data processing or IT services: We share personal data with third parties who support us in providing our Services and help provide, run and manage our internal IT systems. Such third parties may include, for example, providers of information technology, cloud-based software as a service provider, identity management, website hosting and management, data analysis, data back-up, security and storage services. Such organisations include Salesforce and Mambu GmbH, Pay4Later Limited (Deko) Divido Financial Services Limited (Divido) and 1-Fix Limited.
Back-up Servicer: In the event we were to default, we may share your personal data with Equiniti Gateway Limited t/a Equiniti Credit Services, as they act as a back-up servicer for our Services and would ultimately service any customer loan accounts we have in place on behalf of our financing partner.
Payment service providers: We share personal data with third parties who assist us with the processing of payments such as Barclays, Go Cardless and Worldpay.
Retail partners: We share personal information with the retailers you visit and make purchases with. This is done in order to allow us to execute and administer your purchase and administer your relationship with the retailer.
Collections agencies: In the event you were to default on your payments, we may share your personal data with collections agencies who will seek to recover these sums on our behalf. Such agencies include Creditlink Account Recovery Solutions and Phillips & Cohen Associates (UK) Ltd.
Financing partners: We will share personal data with our finance partner, Oaktree Capital.
Partners who have introduced you to us or we have introduced to you: We will share information with some of our partners whom we have introducer arrangements with. We have an arrangement in place with Ecoeus Limited (a company that provides comparison services for boilers and other insurance related products, then introduce you to a trusted local installer) who, as a separate controller, may send marketing communications to you if you have provided your consent to us.
Third-party email marketing and CRM specialists: We share personal data with specialist suppliers who assist us in managing our marketing database and sending out our email marketing communications and membership-related communications including TrustPilot.
Auditors, lawyers, accountants and other professional advisers: We share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in.
Law enforcement or other government and regulatory agencies and bodies: We share personal data with law enforcement. Fraud prevention agencies or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.
Credit Reference Agencies: In order to process your application, we will perform credit and identity checks on you with one or more credit reference agencies. Such agencies include TransUnion. Please see below further information on our arrangements with Credit Reference Agencies
Fraud Prevention & identity verification Agencies: We may check your personal information with fraud prevention agencies. Please see below further information on our arrangements with fraud prevention agencies.

This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties in order to operate our Site and to provide our Services.

11. Credit Reference Agency and fraud prevention agencies

We will exchange your Personal Data (provided to us as set out in this Privacy Notice) with credit reference agencies and fraud prevention agencies in this and the next section. We may also exchange your Personal Data which you have not provided us with credit reference agencies and fraud prevention agencies.

You are entitled to access your personal records held by credit and fraud prevention agencies.

This is not limited to agencies based in the United Kingdom and includes such agencies overseas.

Credit Reference Agencies

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 a loan with 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.

When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.

If you are making a joint application or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application.

CRAs will also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.

The identities of the UK credit reference agencies, their role also as fraud prevention agencies, the data they hold, how they use and share Personal Data, data retention periods and your data protection rights with the Credit reference agencies are explained in more detail within the Credit Reference Agency Information Notice (CRAIN) at https://www.transunion.co.uk/crain

Fraud Prevention Agencies

We share Personal Data with fraud prevention agencies about both active and prospective borrowers.

The Personal Data we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found by viewing the Cifas National Fraud Database fair processing notice (https://www.cifas.org.uk/fpn).

If you provide us with false or inaccurate Personal Data and we suspect any unlawful activity such as fraud or money laundering, this will be recorded, and we may pass details to fraud prevention agencies.

We and other organisations may also access and use this Personal Data to prevent any unlawful activity, such as fraud and money laundering, including when:

checking and verifying your identity;
checking and verifying details on applications for credit, credit related or other financial products and facilities;
managing credit, credit-related or other financial products and facilities; Recovering debt; and
checking details on proposals and claim for all types of insurance.

12. International transfers of personal data

Please note that the personal data that we process may be transferred, stored and/or processed outside of the United Kingdom (“UK”) and/or the European Economic Area (“EEA”). This may be the case for instance if for the purpose of providing our Services, we may need to share your personal data with a third-party supplier or in connection with the use of technical customer support services based outside the EEA. In connection with such transfers, we will always seek to ensure that:

there are appropriate safeguards in place such as binding corporate rules or the standard data protection model contractual clauses between either each of us or between us and the recipient. A copy of the appropriate safeguard can be obtained by contacting us using the contact details set out in section 3; or
an adequacy decision has been made by the United Kingdom or EEA (as applicable) such that the data protection regime in the relevant location or jurisdiction ensures an adequate level of protection for personal information; or
one of the derogations for specific situations in the first sub-paragraph of Article 49(1) UK GDPR (or the equivalent provisions of applicable data protection legislation in the UK) applies to the transfer, storage or processing.

13. HOW LONG WE KEEP YOUR PERSONAL DATA

We store your personal data in accordance with current laws, such as money laundering and accounting law (normally 5 years and 7 years, respectively). We will not retain your personal information for longer than is necessary unless required to by other legal or regulatory requirements or to enable us to adequately investigate complaints.

We may either securely dispose of or destroy your personal data or anonymise it for the purposes of data analytics.

14. CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL DATA

We take the security of your data very seriously and we have rigorous controls in place to ensure that any information we hold on you is held securely. Data is encrypted where appropriate to ensure it remains secure. However, most customers prefer contact via e-mail. You understand that sending information over the internet is not completely secure, and we cannot guarantee the security of your data while it is in transit. We have procedures and security features in place to keep your data secure once we receive it and to mitigate against any risks of it being compromised.

15. HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS

You have the following rights in relation to the personal data we hold about you. If you would like to exercise any of these rights, please contact us using the details set out in How to Contact Us.

Your right of access

If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.

Your right to rectification

If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal data with so that you can contact them directly.

Your right to erasure

You can ask us to delete or remove your personal data in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.

Your right to restrict processing

You can ask us to ‘block’ or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it for a particular purpose. This may not mean that we will stop storing your personal data but, where we do keep it, we will tell you if we remove any restriction that we have placed on your personal data to stop us processing it further. If we’ve shared your personal data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.

Your right to data portability

You have the right, in certain circumstances, to obtain personal data you have provided to us (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer it to a third party of your choice.

Your right to object

You can ask us to stop processing your personal data, and we will do so, if we are:

relying on our own or someone else’s legitimate interest to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or
processing your personal data for the purposes direct marketing.

Your rights in relation to automated decision-making and profiling

You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.

Your right to withdraw consent

If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the How to Contact Us section above or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.

Your right to lodge a complaint with the supervisory authority

If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please contact us using the contact details provided in the How to Contact Us section above. You can also report any issues or concerns to the Information Commissioner’s Office here.

16. CHANGES TO THIS PRIVACY NOTICE

We may make changes to this Privacy Notice from time to time.

To ensure that you are always aware of how we use your personal data, we will update this Privacy Notice from time to time to reflect any changes or proposed changes to our use of your personal data. We may also make changes to comply with changes in applicable law or regulatory requirements.
We encourage you to review this Privacy Notice periodically to be informed of how we use your personal data.