1Introduction
This Privacy Notice explains how Credit Ladder Limited trading as CreditLadder ("CreditLadder", "we", "us" or "our") collects, uses, stores, shares and protects personal data when you use our website, products and services.
CreditLadder is committed to protecting your privacy and processing personal data fairly, lawfully and transparently in accordance with applicable UK data protection legislation, including the UK GDPR and the Data Protection Act 2018.
2Who We Are
Credit Ladder Limited is registered in England and Wales under company number 10074481.
Registered Office:
Hamilton House 4A The Avenue London E4 9LD
ICO Registration Number: ZA205324
Email: help@creditladder.co.uk
For the purposes of UK data protection legislation, CreditLadder is the Data Controller of the personal data described in this Privacy Notice.
3Keeping Your Information Updated
It is important that the personal information we hold about you remains accurate, complete and current.
You should notify us promptly if any of your personal information changes during your relationship with us, including:
your name;
your contact details;
your address;
your tenancy details;
your rent amount;
your landlord details;
your letting agent details;
your managing agent details;
your housing association details; or
the bank account used to pay your rent.
Failure to keep your information up to date may affect our ability to provide the Services, verify rental payments or maintain accurate information within our systems.
Where you provide us with information relating to another individual, such as a landlord, letting agent, managing agent or housing association representative, you confirm that you are entitled to provide that information and that doing so does not breach any applicable law or contractual obligation.
You should also ensure that any information you provide to CreditLadder is accurate and not misleading.
4Personal Data We Collect
We may collect, use, store and share the following categories of personal data.
Identity Data
Includes:
name;
date of birth;
title;
identity verification information;
Contact Data
Includes:
residential address;
billing address;
email address;
telephone number.
Account Data
Includes:
account credentials;
membership selections;
account settings;
subscription information;
account activity.
account identifiers.
Tenancy Data
Includes:
tenancy details;
tenancy start and end dates;
rent amount;
rent payment frequency;
landlord details;
letting agent details;
managing agent details;
housing association details;
tenancy-related information provided by you.
Financial Data
Includes:
payment card information;
bank account information;
Open Banking information provided through authorised Open Banking services.
Transaction Data
Includes:
membership payments;
rent payment information;
transaction information used to verify rent payments;
Cashback Wallet activity;
Rewards Balance activity.
Profile Data
Includes:
preferences;
interests;
survey responses;
feedback;
participation in promotions and competitions.
Technical Data
Includes:
IP address;
browser type and version;
operating system;
device information;
login information;
website interaction data.
Usage Data
Includes information regarding how you use our website, products and services.
Marketing and Communications Data
Includes:
marketing preferences;
communication preferences;
responses to marketing communications.
Aggregated Data
We may create and use anonymous, aggregated statistical information that does not identify any individual.
5Personal Data We Do Not Intentionally Collect
CreditLadder does not intentionally collect or require special category personal data or information relating to criminal convictions or offences in order to provide the Services.
Customers should avoid providing such information when using the Services or contacting us.
If we receive information that is not required for the provision of the Services, we may delete, redact or otherwise limit the processing of that information where appropriate.
Where the processing of such information becomes necessary, we will only process it where permitted by applicable data protection laws.
6How We Collect Personal Data
We collect personal data:
Directly From You
When you:
create an Account;
apply for Services;
purchase a membership;
contact us;
respond to surveys;
enter competitions or promotions;
participate in cashback or rewards programmes.
Through Open Banking
Where you grant permission through Open Banking services.
From Third Parties
Including:
landlords;
letting agents;
managing agents;
housing associations;
identity verification providers;
fraud prevention providers;
payment service providers;
Credit Reference Agencies;
publicly available sources such as Companies House, HM Land Registry and the Electoral Register.
Through Website Technologies
Using cookies, analytics and similar technologies.
Further information is available in our Cookie Policy.
7Open Banking
CreditLadder uses authorised Open Banking services to verify rental payments and provide certain Services.
At the date of this Privacy Notice, CreditLadder uses Open Banking services provided by TrueLayer Limited.
Where you provide the necessary permissions, we may receive information relating to your bank account and transactions for the purposes of:
verifying rental payments;
preventing fraud and misuse of the Services;
providing and administering the Services;
maintaining the accuracy of information reported through the Services; and
complying with legal and regulatory obligations.
The information received may include:
account holder information;
account identifiers;
account information relevant to the verification of rental payments
transaction information; and
payment information relevant to rental payments.
We only access information that is necessary to provide the Services.
Open Banking permissions may expire periodically and may need to be renewed to allow continued use of certain Services.
If you withdraw Open Banking permissions or disconnect your bank account, we may be unable to provide certain Services.
CreditLadder may use third-party service providers to support the delivery of Open Banking functionality. These providers generally act as service providers processing personal data on our behalf under contractual safeguards and applicable data protection laws.
CreditLadder may change Open Banking providers from time to time.
8Lawful Bases for Processing
We only process personal data where a lawful basis applies under UK data protection law.
The lawful bases we rely upon include:
Performance of a Contract
Where processing is necessary to:
create and administer your Account;
provide memberships and Services;
verify rental payments;
report rental payment information;
administer Cashback and Rent Rewards;
process payments;
provide customer support.
Legitimate Interests
Where processing is necessary for our legitimate interests, including:
fraud prevention and detection;
maintaining the security of the Services;
improving our products and services;
service administration;
customer communications;
business planning and analytics;
exercising or defending legal rights.
Before relying on this lawful basis, we consider and balance any potential impact on your rights and freedoms.
Legal Obligation
Where processing is necessary to comply with legal or regulatory obligations including:
anti-fraud obligations;
tax obligations;
regulatory reporting requirements;
court orders and lawful requests from public authorities.
Consent
Where required by law, we will obtain your consent before:
sending certain marketing communications;
sharing personal data with selected third parties for their own marketing purposes; or
undertaking any processing activity where consent is the appropriate lawful basis.
Where processing relies upon consent, you may withdraw that consent at any time.
9How We Use Personal Data
We may use your personal data for the following purposes:
Providing the Services
To:
create and administer your Account;
provide memberships and related Services;
verify rental payments;
administer Cashback and Rent Rewards;
process subscription payments;
provide Rent Statements; and
communicate with you regarding your Account and Services.
Lawful Basis: Performance of a contract.
Rent Reporting
To:
verify rental payment information;
maintain records of verified rental payments;
report rental payment information to participating Credit Reference Agencies; and
maintain the accuracy of information supplied through our rent reporting services.
Lawful Basis: Performance of a contract and legitimate interests.
Fraud Prevention and Security
To:
detect, prevent and investigate fraud;
verify customer identities;
verify tenancy information;
verify landlord, letting agent, managing agent or housing association information;
monitor misuse of the Services; and
maintain the security of our systems and Services.
Lawful Basis: Legitimate interests and legal obligations where applicable.
Customer Support and Service Administration
To:
respond to enquiries;
resolve complaints;
provide customer support;
notify you of changes to our Services, Terms or Privacy Notice; and
administer promotions, surveys and competitions.
Lawful Basis: Performance of a contract, legitimate interests and legal obligations where applicable.
Service Improvement
To:
analyse how customers use the Services;
improve our products and features;
develop new Services;
measure performance;
conduct analytics;
create anonymous statistical information; and
support business planning.
Lawful Basis: Legitimate interests.
Marketing
To send information about products, services and offers that may be relevant to you.
Lawful Basis: Legitimate interests and consent where required by law.
Further information is set out in Section 13.
Legal and Regulatory Compliance
To:
comply with legal obligations;
respond to lawful requests from regulators and public authorities;
comply with tax and accounting requirements;
establish, exercise or defend legal claims; and
maintain appropriate records.
Lawful Basis: Legal obligation and legitimate interests.
10Rent Verification and Credit Reporting
CreditLadder processes and shares rental payment information with participating Credit Reference Agencies on the basis of the performance of its contract with Customers and its legitimate interests in providing rent reporting services and maintaining the accuracy of information supplied through those services.
These may include:
and any replacement or additional Credit Reference Agencies used by CreditLadder from time to time.
Such organisations act as independent controllers of the information they receive and process it in accordance with their own privacy notices.
You should review the privacy information published by each Credit Reference Agency to understand how your information is used.
Further information regarding how Credit Reference Agencies collect, use, share and retain personal data can be found in their respective Credit Reference Agency Information Notices (CRAIN), available below:
Experian – Credit Reference Agency Information Notice (CRAIN)
Equifax – Credit Reference Agency Information Notice (CRAIN)
TransUnion – Credit Reference Agency Information Notice (CRAIN)
11Third-Party Providers and Partners
CreditLadder works with a number of third-party providers to help deliver the Services.
We may share personal data with the categories of organisations described below.
Referral Partners and Member Benefits
CreditLadder may introduce customers to third-party providers from time to time, including:
mortgage advisers;
insurance providers;
cashback providers;
employee and member benefit providers;
financial services providers; and
other commercial partners.
Where you choose to engage with these services, relevant personal data may be shared with the provider where necessary to facilitate the service requested by you.
In most cases, once the provider receives your information in order to provide services directly to you, it will act as an independent Data Controller and process personal data in accordance with its own privacy notice and terms.
Service Providers Acting on Our Behalf
CreditLadder may use service providers to support the delivery of the Services, including providers of:
cloud hosting services;
payment processing services;
identity verification services;
fraud prevention services;
communications services;
analytics services;
IT support services; and
professional advisory services.
These organisations process personal data on our behalf and in accordance with contractual obligations and applicable data protection laws.
Regulators and Legal Authorities
We may share personal data with:
regulators;
courts;
tribunals;
government bodies; and
law enforcement agencies,
where required by law or where necessary to establish, exercise or defend legal claims.
12Marketing
We may use personal data to send information about products, services and offers that may be relevant to you.
You can opt out of marketing communications at any time by:
updating your Account preferences;
using unsubscribe links;
contacting help@creditladder.co.uk.
We will obtain consent where required by law.
We will not share your personal data with third parties for their own marketing purposes without your consent.
13International Transfers
Some of the organisations that support the delivery of our Services may process personal data outside the United Kingdom.
These may include providers of:
cloud hosting services;
communications services;
analytics services;
customer support services;
fraud prevention services; and
other technology services used by CreditLadder.
Where personal data is transferred outside the United Kingdom, we take steps to ensure that it remains appropriately protected and is handled securely.
When transferring personal data internationally, we rely on one or more recognised legal safeguards, including:
UK adequacy regulations;
the UK International Data Transfer Agreement (IDTA);
the UK Addendum to Standard Contractual Clauses; or
other transfer mechanisms recognised under UK data protection law.
We only transfer personal data internationally where we are satisfied that appropriate safeguards are in place.
Further information regarding international transfers and the safeguards used is available upon request.
14Data Security
We implement appropriate technical and organisational measures designed to protect personal data against:
unauthorised access;
accidental loss;
destruction;
misuse;
disclosure;
alteration.
Access to personal data is limited to those with a genuine business need.
15Data Retention
We retain personal data only for as long as necessary to fulfil the purposes described in this Privacy Notice, including legal, regulatory, accounting and reporting requirements.
The retention periods below provide a summary of our standard approach.
| Data Category | Typical Retention Period |
|---|---|
| Account Data | 6 years after account closure |
| Contact Data | 6 years after account closure |
| Tenancy Data | 6 years after account closure |
| Financial Data | 6 years after account closure |
| Transaction Data | 6 years after account closure |
| Rent Reporting Data | 6 years after reporting ends |
| Customer Support Records | Up to 6 years after resolution |
| Marketing Preferences | Until withdrawn or for up to 2 years after last interaction |
| Cashback Wallet Records | 6 years after account closure |
| Rewards Balance Records | 6 years after account closure |
| Fraud Prevention Records | Up to 6 years after account closure or longer where required by law |
Retention periods may be extended where necessary to comply with legal, regulatory, fraud prevention or dispute resolution requirements.
We may retain personal data for longer where necessary to:
comply with legal or regulatory obligations;
investigate fraud;
resolve disputes;
establish, exercise or defend legal claims; or
comply with requests from public authorities.
Where personal data is no longer required, it will be deleted, anonymised or securely destroyed.
We may retain anonymised statistical information indefinitely where such information no longer identifies any individual.
16Your Data Protection Rights
Under UK data protection law, you have the right to:
access the personal data we hold about you;
request correction of inaccurate personal data;
request deletion of personal data in certain circumstances;
request restriction of processing;
object to processing;
request portability of certain personal data; and
withdraw consent where processing relies on consent.
To exercise any of these rights, please contact:
We may ask you to provide information necessary to verify your identity before responding to your request.
We will normally respond within one month, although this period may be extended where permitted by law.
17Complaints
If you have any questions or concerns about how we process your personal data, please contact us at:
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO):
Website: https://www.ico.org.uk
18Changes to this Privacy Notice
We may update this Privacy Notice from time to time.
The latest version will always be available on our Website and will include the date of the most recent update.
Where required by law, or where changes materially affect how we process personal data, we will take appropriate steps to notify affected individuals. We encourage you to review this Privacy Notice periodically.