Lightbulb Credit Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.lightbulbcredit.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is deemed to occur upon your first use of Our Site and also if you, or the organisation you work for, enter into an agreement with us. This Privacy Policy will apply to all personal data received by us through the Site, directly or as part of any agreement we may enter into with you or the organisation you work for. If you, or the organisation you work for, have not entered into an agreement with us and you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately. When entering into an agreement with you or the organisation you work for, we will ask for a reconfirmation of acceptance and agreement of this Privacy Policy.

In this Policy the following terms shall have the following meanings:

“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 15, below; and

“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

Our Site is owned and operated by Lightbulb Credit Ltd a company incorporated in England with registered number 11018627 and having its registered office at Bramley House Bramley Road, Long Eaton, Nottingham, England, NG10 3SX.

This Privacy Policy applies when we receive any personal information from you or the organisation you work for. This may arise directly through our Site or otherwise (for example from our entering into an agreement with the organisation you work for). Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

Personal data is defined by (i) the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (the “UK GDPR”), as it forms part of the law of England and Wales, Scotland, and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018, and (ii) the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

a) The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 16.

b) The right to access the personal data we hold about you. Part 14 will tell you how to do this.

c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 16 to find out more.

d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 16 to find out more.

e) The right to restrict (i.e. prevent) the processing of your personal data.

f) The right to object to us using your personal data for a particular purpose or purposes.

g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 16.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 16.

Depending upon your use of Our Site an any agreement between the organisation you work for and us, we may collect and hold some or all of the personal and non-personal data set out below and using the methods set out. Please also see Part 15 for more information about our use of Cookies and similar technologies. We do not collect any ‘special category’ or ‘sensitive’ personal data, personal data relating to children or data relating to criminal convictions and/or offences.

We may collect the following data about you:

Contact details: your name, address, email address, and telephone number so that we can contact you in response to an enquiry made via our Site or in relation to the services that we have from time to time agreed to provide to the organisation you work for;

Correspondence: we collect any additional personal data you or the organisation you work for may provide to us from time to time if you/they contact us by email, letter or telephone, through our Site, by submitting a comment on our Site, or by any other means;

Survey responses: information from surveys that we use for research purposes, if you choose to respond to them;

Details of visits to the Site: details of your visits to our Site, including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The remainder of this Part 7 describes how we may use your personal data, and Part 8 sets out our lawful bases for doing so.

• To provide you with the services requested - We use your personal data to accept the organisation you work for as a new or returning customer and to provide them with the services they have requested in accordance with any agreement between us.

• To send you service communications including in relation to changes to our services - We use the contact details provided to us so that we can communicate with you about the services that we provide, including to let you know about major changes to those services or to any related information.

• Direct marketing - If you have provided your consent or we otherwise have the right to do so, we may use your contact details to send you direct marketing by email, SMS, post or telephone relating to our services.

You can unsubscribe from our direct marketing at any time by clicking the “Unsubscribe” link in any of our emails or by contacting us.

• To track your usage of our website, communications and services - We use Cookies and similar technologies to track your activity on our Site so that we can provide important features and functionality on our Site, monitor its usage, and provide you with a more personalised experienced.

• To provide and improve customer support - We use your personal data to be able to provide and improve the customer support we provide to you/the organisation you work for (for example, where you have questions about our services).

• To maintain our records and improve data accuracy - Like any business, we process personal data in the course of maintaining and administering our internal records. This includes processing your personal data to ensure that the information we hold about you/the organisation you work for is kept up to date and accurate.

• To respond to enquiries, complaints and disputes - We use the personal data we hold about you to help us respond to any enquiries or complaints you/the organisation you work for have made, or deal with any dispute which may arise in the course of us providing our products and services to you/them, in the most effective manner.

• To investigate, detect and prevent fraud and comply with our legal obligations - In certain circumstances, we use your personal data only to the extent required in order to enable us to comply with our legal obligations, including for fraud detection, investigation and prevention purposes. This may require us to provide your personal data to law enforcement agencies if they request it.

You will not be sent any unlawful marketing or spam. we will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

Third Parties whose content appears on our Site may use third-party Cookies, as detailed below in Part 15. Please refer to Part 15 for more information on controlling Cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 16.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

We collect and use your personal data on one or more of the following lawful bases:

• you have granted your consent;

• it is necessary for the performance of a contract and to comply with our legal obligations, which basis we rely on for example:

o to provide the organisation you work for with agreed services;

o to communicate with you about the services we are providing to the organisation you work for, including to let you know about major changes to those services and related information; and

o to provide and improve client support;

if you choose not to give some or all of the information to us, this may affect our ability to provide our services to you; and

• it is necessary for the purposes of our legitimate business interests which interests may include:

o providing the organisation you work for with services that are as useful and beneficial as possible, including by personalising our contact with you and making sure we tell you about all the offers that are relevant to you;

o better understand our client base so that we can improve our services and marketing activities (which could also benefit you/the organisation you work for);

o comply with our contractual obligations to third parties;

o develop and improve our Site to enhance the client experience;

o train our staff so that we can provide you with a better client service;

o respond to any enquiries or complaints you have made, or deal with any dispute which may arise in the course of us providing our services to the organisation you work for; and

o to ensure that content from our Site is presented in the most effective manner for you and for your computer; and

o ensure effective operational management and internal administration of our business, document retention, compliance with regulatory guidance and exercise or defence of legal claims.

Where we think there is a risk that one of your interests or fundamental rights and freedoms may be affected we will not process your personal data unless there is another legal ground for us to do so (either that we have obtained your consent to the processing or it is necessary for us to perform our contract with you or to comply with our legal obligations).

We will not keep your personal data for any longer than is necessary having regard to the reason(s) for which it was first collected. In practice, this means different types of personal data may be kept for different periods (and where the following factors will be used to determine how long it is kept):

• legal obligation(s) under applicable law to retain data for a certain period of time;

• statute of limitations under applicable law;

• potential or actual disputes; and

• guidelines issued by relevant data protection authorities.

We will, subject as below, only store your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.

We may store some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

• limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality; and

• procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:

• To third parties (including credit reference agencies) as specified in any agreement for services entered into between us;

• If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Statement.

• In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 9.

12.1 In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details).

12.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

You may access all of Our Site without providing any personal data at all. However, to sign up to any service or similar via Our Site, or for the organisation you work for to do so, you may be required to submit or allow for the collection of certain data.

You may restrict our use of Cookies. For more information, see Part 15.

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 16.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request as soon as practicable and, in any case, not more than one month after receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our services. We carefully chose these Cookies and take steps to ensure that your privacy and personal data is protected and respected at all times.

All Cookies used by and on Our Site are used in accordance with current Cookie Law.

Before Cookies are placed on your computer or device, you will be shown a prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.

The Cookies we use on Our Site are grouped into the following categories:

• Essential– Some of the cookies on Our Site are essential for us to be able to provide you with a service you have requested. An example of this could be a cookie used to allow communication between your browser and Our Site where you submit a request to us through Our Site. Our cookie preference Cookie in the prompt noted above is also an essential Cookie. You may not be able to use Our Site without these Cookies.

• Analytics– We use analytics Cookies to helps us understand how users engage with Our Site. An example is counting the number of different people coming to Our Site or using a particular feature, rather than the total number of times the site or feature is used. Without this Cookie, if you visited Our Site once each week for three weeks we would count you as three separate users. We would find it difficult to analyse how well Our Site was performing and improve it without these cookies.

In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Email address: enquiries@lightbulbcredit.com.

Telephone number: 0115 6970825.

Postal Address: Bramley House, Bramley Road, Long Eaton, Nottingham NG10 3SX.

We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and we recommend that you check this page regularly to keep up-to-date as it is your responsibility to review the amended Privacy Policy. You will be deemed to have accepted the amended terms of the Privacy Policy on your first use of Our Site following the alterations. This Privacy Policy was last updated on 8th December 2021.