Credit Score Privacy Notice

The credit score function in the Lowell app presents existing Lowell customers with their credit score from one of the main UK credit reference agencies (CRAs), TransUnion We call this your “TransUnion Credit Score” in this notice.

Your TransUnion Credit Score is a number between 1 and 710 that TransUnion calculates according to the factual information on your credit report which it receives from various data sources.

The TransUnion Credit Score you see in the Lowell mobile app may be different from the credit scores you see elsewhere that may be calculated for you by the other CRAs (Experian and Equifax).

You must be an existing Lowell customer who has downloaded the Lowell mobile app to access your TransUnion Credit Score.

Your credit report contains all of the information a credit reference agency (CRA) holds on you under your name and address; this includes information on how well you have managed with borrowing money in the past, whether you are registered to vote (known as being on the electoral roll), who has viewed your credit report, why they have viewed it, what they have viewed and when they viewed it.

The CRAs create a credit report for you based on information supplied to them by lenders, utilities providers and other public sources, including electoral register information and any judgments, insolvencies, and bankruptcies.

A credit score is calculated from the information in your credit report; it gives a general picture of your current financial position.

Yes, different organisations, you have a financial relationship with, may use their own rules to calculate a credit score for you. Each of the credit reference agencies (TransUnion, Experian and Equifax) have their own rules for calculating a credit score for you. The score we're showing you in the Lowell mobile app is calculated by TransUnion.

Lowell is Lowell Financial Ltd. Lowell operates the Lowell mobile app.  We call this “the Lowell app” in this notice.

We make the Lowell app available to our customers:

• to provide you with information about being a Lowell customer and what it means for you
• so that you can use it to manage your account with us and make payments.

Lowell Financial Ltd is part of the Lowell group of companies.  We manage customer accounts on behalf of Lowell Portfolio I Ltd which is another company in the Lowell group.

Lowell Portfolio I Ltd buys customer accounts where there is an outstanding balance from a wide range of organisations including banks, retailers and credit card, mobile phone, home shopping and utility (gas, electricity and water) companies.

Lowell Financial Ltd manages the accounts, which means that if we write or speak to you or if you use this app, it will usually be Lowell Financial Ltd that you are dealing with.

We also provide credit management solutions to other companies to help them manage the accounts that you have with them.

Lowell is not responsible for the content of your TransUnion Credit Score.

TransUnion is TransUnion International UK Limited.

TransUnion is part of the TransUnion group of companies.  TransUnion is one of the UK’s major credit reference agencies (CRAs). CRAs hold details of an individual’s credit history at their addresses.  Local authorities, courts, and credit providers share information with CRAs to promote responsible lending, support debt recovery, and to prevent over-indebtedness and fraud. TransUnion is responsible for calculating your TransUnion Credit Score.

Lowell and TransUnion are independent controllers of your personal data.

For more information about how TransUnion use your personal data, please see their privacy notice which is available at https://www.transunion.co.uk/legal-information/bureau-privacy-notice.

The Lowell app allows you to make a data subject access request (under UK GDPR) to TransUnion to view your TransUnion Credit Score, should you wish to do so. It is not a full data subject access request for all information held by TransUnion about you. It will only include the information contained in your TransUnion Credit Score.

When you request your TransUnion Credit Score in the Lowell app, this will leave what is called a soft footprint on your credit report.  This shows that Lowell requested your TransUnion Credit Score on your behalf. This will occur without you requesting your Credit Score directly from TransUnion.

Soft footprints can usually only be seen by you, the organisation which has created the soft footprint, and the credit reference agency which has provided the credit data (TransUnion provide this in the Lowell app).  When an organisation collects your credit score for you, they see everything that you can see, including all the soft footprints on your credit report.

The soft footprint is left so you can see when your data has been accessed, by whom and when.  It is not used by any lenders in any lending decisions and will not affect your credit score.

The soft footprints on your credit report are made available to Lowell even if they have been created by another organisation. 

If you get your credit score from any other organisation, they will be able to see the soft footprint left by Lowell.

You can access the TransUnion Credit Score function at any time via the Lowell app.  When you access it for the first time, you will be asked to provide some further information via the Lowell app which will be shared with TransUnion.  TransUnion will use this information to confirm your identity and make sure that you are provided with the correct information.

If TransUnion is unable to confirm your identity, you will not be able to access your TransUnion Credit Score. If this happens, neither TransUnion nor Lowell will be able to tell you why TransUnion has been unable to confirm your identity. Although it may be due to TransUnion not being able to match your personal details to the correct credit profile on its database.

If you wish to access your credit information from TransUnion, but you do not wish to provide further information to confirm your identity via the Lowell app, you can request a copy of your statutory credit report at https://www.transunionstatreport.co.uk/CreditReport/AboutYou.

If you register for your TransUnion Credit Score through the Lowell app, TransUnion will provide the information to Lowell for us to show you in the Lowell app.  This means that the soft footprints on your credit report are made available to Lowell, even if they have been created by another organisation. 

We will only use the information contained in your TransUnion Credit Score to display this information to you in the Lowell app.  We only retain the data for as long as you have the information open in the Lowell app.  This means that if you submit a request to exercise any of your rights under the data protection legislation to Lowell, the information in your TransUnion Credit Score will not be covered.

We will never use your TransUnion Credit Score to manage your Lowell accounts or make any decisions (including automated decisions) about you or your account. We will also never use your TransUnion Credit Score for any form of marketing.

The request for your TransUnion Credit Score will leave a soft footprint on your credit file. This will occur without you requesting your credit score directly from TransUnion.  Other organisations that you use to obtain your credit report and credit score will be able to see the soft footprint left by Lowell. However, if you make a request to TransUnion directly to view your own credit report, this is not visible to organisations that assess an application for credit nor will it have an impact on your score.

TransUnion will update your TransUnion Credit Score and send this to Lowell every seven days  so that you have the most up-to-date information.

The TransUnion Credit Score is calculated by TransUnion using the data TransUnion holds in your credit report.   You can check your credit report by going to https://www.transunionstatreport.co.uk/CreditReport/AboutYou.  If, after you've reviewed your credit report you feel something is inaccurate, you can raise a dispute by contacting TransUnion at ukconsumer@transunion.com.

In the Lowell app, you will see a “What’s New?” section which will show anything in your TransUnion Credit Score which has changed.  If you need more information, you will need to contact TransUnion’s Support and Help Desk Service by email at UKConsumer@transunion.com.

No, you can only obtain your own TransUnion Credit Score.

You can opt out of receiving your TransUnion Credit Score at any time by clicking on “Opt Out”.  

If your TransUnion Credit Score is temporarily unavailable, we will send you a message via the Lowell app to let you know.

If Lowell decides to stop providing the credit score function as a service in the Lowell app, you will no longer be able to access your TransUnion Credit Score in the Lowell app.

iovation Inc is part of the TransUnion group of companies.  They help TransUnion to detect and combat online fraud and other types of cybercrime.  They collect information about your device and your IP address. They use this information to spot whether someone else may be trying to access your credit report and stop them accessing your credit report. 

For more information about how TransUnion and iovation Inc use your personal data, please see their privacy notices which are available at www.transunion.co.uk/legal-information/bureau-privacy-notice and at www.iovation.com/privacy respectively.

For more information about the cookies and similar technologies that Lowell set, please see our mobile app privacy notice

The Lowell mobile app is operated by Lowell Financial Ltd:

• to provide you with information about being a Lowell customer and what it means for you and
• so that you can use it to manage your account with us and make payments.

Where we use “Lowell”, “we”, “our” or “us” in this privacy notice, we mean Lowell Financial Ltd unless we say otherwise.  Where we use “this app”, we mean the Lowell mobile app.

Lowell Financial Ltd is part of the Lowell group of companies.  We manage customer accounts on behalf of Lowell Portfolio I Ltd which is another company in the Lowell group.

Lowell Portfolio I Ltd buys customer accounts where there is an outstanding balance from a wide range of organisations including banks, retailers and credit card, mobile phone, home shopping and utility (gas, electricity and water) companies.

Lowell Financial Ltd manages the accounts, which means that if we write or speak to you or if you use this app, it will usually be Lowell Financial Ltd that you are dealing with.

We also provide credit management solutions to other companies to help them manage the accounts that you have with them.

TransUnion is TransUnion International UK Limited.

TransUnion is part of the TransUnion group of companies.  TransUnion is one of the UK’s major credit reference agencies (CRAs). CRAs hold details of an individual’s credit history at their addresses.  Local authorities, courts, and credit providers share information with CRAs to promote responsible lending, support debt recovery, and to prevent over-indebtedness and fraud. TransUnion is responsible for calculating your TransUnion Credit Score.

Lowell and TransUnion are independent controllers of your personal data.

For more information about how TransUnion use your personal data, please see their privacy notice which is available at https://www.transunion.co.uk/legal-information/bureau-privacy-notice.

We collect the information you provide directly to us when you register for your TransUnion Credit Score and we obtain your TransUnion Credit Score from TransUnion.
We collect the information provided by TransUnion in respect of your TransUnion Credit Score to share it with you.

For more information about how TransUnion uses your personal data, please see their privacy notice which is available at www.transunion.co.uk/legal-information/bureau-privacy-notice.

For more details about the information we collect about you as a Lowell customer, please see our customer privacy notice and as a user of this app, please see our mobile app privacy notice

When you register for your TransUnion Credit Score, we use the address information we already hold for you and we also collect your telephone number.

We also collect the content of your TransUnion Credit Score.

iovation Inc is part of the TransUnion group of companies. They help TransUnion to detect and combat online fraud and other types of cybercrime. They collect information about your device and your IP address. They use this information to spot whether someone else may be trying to access your credit report and stop them accessing your credit report.

For more information about how TransUnion and iovation Inc use your personal data, please see their privacy notices which are available at www.transunion.co.uk/legal-information/bureau-privacy-notice and at www.iovation.com/privacy respectively.

We may also combine the information you give us and the information we collect about you with information that we receive from other sources, such as the previous owner of your account.

For more detail about the information we collect about you as a Lowell customer, please see our customer privacy notice and as a user of this app, please see our mobile app privacy notice.

We need the information we collect when you register for your TransUnion Credit Score so that we can submit your request to TransUnion. TransUnion need this information so that it can confirm your identity and match your information with the correct credit profile on its database.

We need the information provided by TransUnion to show you your TransUnion Credit Score.

iovation Inc is part of the TransUnion group of companies. They help TransUnion to detect and combat online fraud and other types of cybercrime. They collect information about your device and your IP address. They use this information to spot whether someone else may be trying to access your credit report and stop them accessing your credit report.

For more information about how TransUnion and iovation Inc use your personal data, please see their privacy notices which are available at www.transunion.co.uk/legal-information/bureau-privacy-notice and at www.iovation.com/privacy respectively.

By agreeing to our terms and conditions for the use of this app and the TransUnion Credit Score, you have entered into a contract with us. We need the information above to provide you with the TransUnion Credit Score under those terms and conditions. For more detail about why we need the information we collect about you as a Lowell customer, please see our customer privacy notice and as a user of this app, please see our mobile app privacy notice.

We share the information that you provide directly to us when you register for your TransUnion Credit Score with TransUnion.

TransUnion share the content of your TransUnion Credit Score with us.

iovation Inc is part of the TransUnion group of companies. They help TransUnion to detect and combat online fraud and other types of cybercrime. They collect information about your device and your IP address. They use this information to spot whether someone else may be trying to access your credit report and stop them accessing your credit report.

For more information about how TransUnion and iovation Inc use your personal data, please see their privacy notices which are available at www.transunion.co.uk/legal-information/bureau-privacy-notice and at www.iovation.com/privacy respectively.

We also use a number of carefully selected third parties to supply us with IT products and services. We will only share your information with our suppliers where it is necessary for them to provide us with the services we need.

For more detail about who we share your information with as a Lowell customer, please see our customer privacy notice and as a user of this app, please see our mobile app privacy notice.

The information that we do collect about you is generally stored on servers and filing systems in the UK but from time to time it may be stored in or accessed from countries outside the UK. Where this may happen, we always make sure that there are appropriate safeguards in place, such as the Standard Contractual Clauses or binding corporate rules, to guarantee that your information – and your rights – are protected to the same high standard as under UK law.

If you register for your TransUnion Credit Score through the Lowell app, TransUnion will provide the information to Lowell for us to show you in the Lowell app.  This means that the soft footprints on your credit report are made available to Lowell even if they have been created by another organisation. 

We only retain the data for as long as you have the information open in the Lowell app. 

For more detail about how long we keep your information as a Lowell customer, please see our customer privacy notice and as a user of this app, please see our mobile app privacy notice.

We do not carry out any profiling or automated decision-making in respect of the information we collect in respect of your TransUnion Credit Score.

For more details about the profiling and automated decision-making we carry out in respect of the information we hold about you as a customer, please see our customer privacy notice and as a user of this app, please see our mobile app privacy notice

Under the data protection laws, you have a number of rights in respect of your information, which include the right to:

• access the information which we hold about you
• ask us to make changes to the information we hold about you to make sure that it is accurate and up to date
• delete or erase your information (sometimes called the right to be forgotten)
• stop or restrict our processing of your information
• object to our processing your information
• not be subject to automated decision-making and
• request the transfer of some of the information we hold about you (known as data portability).

Some of these rights only apply in certain situations. For more details about how these rights apply to the way we use the information we hold about you, please see our Customer Privacy Notice.

If you would like to exercise any of your rights, please contact our Data Protection Officer by:

• email to dpo@lowellgroup.co.uk
• letter to Data Protection Officer, Lowell Financial Ltd, PO Box 13079, Harlow, CM20 9TE.

You can opt out of receiving your TransUnion Credit Score at any time by clicking on “Opt Out”.

If you have any questions, concerns or complaints about the way we process your personal information, please contact our Data Protection Officer in the first instance by

• email to dpo@lowellgroup.co.uk
• letter to Data Protection Officer, Lowell Financial Ltd, PO BOX 1411, Northampton, NN2 1BQ

and they will do their very best to help you.

If you are not happy with the way we have handled your complaint or are still concerned about our handling of your personal information, you have a right to take your complaint to the Information Commissioner’s Office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF and www.ico.org.uk.

We will regularly review this notice and keep it updated to make sure that the information we provide you with is accurate and up to date.

This notice was last reviewed and updated in May 2021.